HISTORICAL RETROSPECTIVE OF THE LEGAL REGULATION OF PERSONAL DATA IN SOME COUNTRIES

Abstract

The article analyzes the evolution of legislation in the field of personal data processing in different countries of the world. The prerequisites for the emergence of national regulations regulating the protection of personal information are investigated. The influence of information and com- munication technologies on the development and change of public relations related to the processing of personal data is considered. The formation of legislation in the field of personal data protection in Europe is being investigated. The formation of legislation on the protection of personal information in the United States of America is analyzed, the California Consumer Privacy Act is considered. In addition, the article examines the legislation of the People’s Republic of China related to the protection of personal data. The article examines the main provisions of the legal regulation of personal data in the countries under consideration, identifies legal structures that significantly enhance the effectiveness of the approaches used to regulate the turnover of personal data. Among such constructions, it is possible to distinguish the division of personal data into categories, according to the degree of importance, categorization of information systems processing personal information, mandatory audit of such systems, rules related to notifying users about the data trans- ferred to third parties, mandatory compensation by personal data operators for damage to owners due to their leakage.

The use of advanced foreign experience will have a positive impact on improving the protection of personal data of citizens, which is why, in the process of reviewing foreign legislation, attention is focused on legal approach- es, the adaptation of which to Russian legislation would make the protection of personal data more effective and complete. This necessity relates to the fact that the Russian legislation regulating the turnover of personal data requires speedy improvement, since public relations in this area have radically changed, including due to the widespread intro- duction of automated processing of personal information.
It is the widespread introduction of automated processing
of personal data that is the factor that has had a significant impact on the revision of approaches to the protection of personal data in different countries.