The Tour d’ Horizon of Data Law Implications of Digital Twins
One may be familiar with Marvel Comics character“ Iron Man,” who designed his suit using a 3D hologram model [ 1 ]. This fictional idea of a virtual replica has now culminated into a reality in the form of‘ Digital Twins.’ Bridging the gap between the physical and virtual realms,‘ Digital Twins’ has become a buzzword in numerous industries from healthcare to aerospace to energy to manufacturing.
A Digital Twin(“ DT”) is a virtual replica of real-world applications. Cars, humans, supply chain, telecom networks, business processes, and even entire cities can have their DTs. Global DT market size is projected to grow from USD 17.73 billion in 2024 to USD 259.32 billion by 2032, forecasting a CAGR of 39.8 % [ 2 ].
DTs are data intensive applications and may have several implications under various data laws globally. This article aims to provide a broad overview of the data law considerations( privacy and sectoral laws) for digital twins across various jurisdictions.
1 UNDERSTANDING AND CATEGORIZING DTS
The first known use of a DT was by the National Aeronautics and Space Administration in the 1960s for the Apollo 13 mission, where 15 simulators were used to replicate the physical spacecraft ' s conditions [ 3 ]. The Digital Twin Consortium 1 has defined a DT as“ an integrated datadriven virtual representation of real-world entities and processes, with synchronized interaction at a specified frequency and fidelity.” 2 The international standard ISO / IEC 30173:2023 on Digital twin – Concepts and terminology also provides for a definition of digital twins. 3 However, the acceptance of this definition is subject to the acceptance of the international standard by the respective countries.
To put simply, a common man may perceive a DT as a“ replica” of a physical product or process, continuously updated with real-time data from the physical counterpart. Typically, depending upon the utility and type of the DT, it may be facilitated or supported by various technologies including Internet of Things(“ IoT”) devices like sensors for data collection, cloud computing for data storage and retrieval, Artificial Intelligence(“ AI”) for data analytics and immersive technologies( augmented, virtual and mixed reality) to create virtual replicas [ 4 ].
Against this backdrop, it is pertinent to note that DTs may be broadly classified as follows.
1
Official website of the Digital Twin Consortium. https:// www. digitaltwinconsortium. org
2
Definition of a Digital Twin, Digital Twin Consortium. https:// www. digitaltwinconsortium. org / initiatives / the-definition-of-a-digital-twin /
3
ISO / IEC 30173:2023 Digital twin – Concepts and terminology. https:// www. iso. org / standard / 81442. html
72 May 2025