PERSONAL DATA PROTECTION: A CHANGING CONCEPT IN THE UNITED STATES, GERMAN-EUROPEAN, AND BRAZILIAN MODELS
Palavras-chave:
Fundamental right, Personal data protection, American law, German-European law, Brazilian law.Resumo
Objective: This article aim to describe and analyse three different models of regulating the personal data protetion, the American, the German-European, and the Brazilian models.
Methodology: This text is based on a review of national and foreign literature and documentary research.
Results: The article provides some critical considerations regarding the effectiveness of the personal data protetion in all this models.
Contributions: The main contribution of this text is to present and analyze the evolution of the concept and the right to personal data protection in three different legal models, considering that there are normative provisions, however, with low effectiveness.