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Laws On Erasure Of Online Information: Canada, France, European Union, Germany, Israel, Japan, New Zealand, Norway, Portugal, Russia, Spain, United Kingdom, Luis Acosta
Copyright, Fair Use, Scholarly Communication, etc.
Comparative Summary by Luis Acosta, Chief, Foreign, Comparative, and International Law Division II, Law Library of Congress (United States), Global Legal Research Center
This report describes the laws of twelve jurisdictions that have some form of remedy available enabling the removal of online data based on harm to individuals’ privacy or reputational interests, including but not limited to defamation. Six of the countries surveyed are within the European Union (EU) or the European Economic Area, and therefore have implemented EU law. Five non-EU jurisdictions are also surveyed.
Comparative analysis across jurisdictions presents terminological challenges, because legal language across jurisdictions seems …