Examination of Extraterritorial Legislation of the Right to be Forgotten in Digital Age
The risk of losing control of personal information in the digital age has compelled the creation of the new emerging right known as "the right to be forgotten". This right first took shape in the European U-nion and was judicially affirmed after the González case in 2014. It was later incorporated into the General Data Protection Regulation of 2016 and applied in subsequent cases. The United States has taken a more cau-tious approach to the right to be forgotten,with California enacting legislation that recognizes it in a limited manner. Russia has actively pursued legislation for the right to be forgotten by introducing a dedicated "Right to be Forgotten Law" with corresponding case law. Japan was the first to recognize the right through judicial decisions and later acknowledged it to a limited extent in legislation. Although Chinese legislators have not used the name "right to be forgotten",they have embracedits core principles. From the legislative and judicial practices of various countries,the recognition of the right to be forgotten meets the real needs of the digital age and has been widely acknowledged or adopted.
right to be forgottenpersonal information protectiondeletiondigital age
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