Comparative Analysis of the Right to Privacy in the U.S. and Europe

Abstract

This paper provides a comparative analysis of the right to privacy in the United States and Europe, highlighting the significant differences in legal frameworks and cultural perceptions. Privacy is recognized as a fundamental human right in both regions; however, the U.S. emphasizes individualism and procedural protections, while Europe adopts a more principled approach rooted in social responsibility. The historical evolution of privacy rights reflects sociopolitical changes, technological advancements, and landmark legal decisions. In the U.S., privacy protections are derived from various constitutional amendments, while in Europe, the European Convention on Human Rights and the General Data Protection Regulation (GDPR) establish comprehensive protections. The paper examines key cases and legislation that have shaped privacy rights and identifies challenges posed by emerging technologies and data security issues. As globalization intensifies, the need for harmonized privacy standards becomes crucial. The analysis concludes with recommendations for fostering international dialogue among stakeholders to ensure effective privacy protection in an increasingly interconnected world.

Keywords: Right to Privacy, United States, Europe, GDPR, Constitutional Law, Data Protection, Privacy Frameworks.