Comparative analysis of privacy law between the United States and the EU. What will be the best practice for Armenia? Whether GDPR as an evolution of Data Protection and United States regulations of Data Protection ensure the right of informational self-determination?

Abstract

The right of data protection which was recognized by the majority of countries at the beginning of the 20th century immensely evolved. Most of the countries either separately or in cooperation with each other take appropriate measures to ensure the protection of personal data without precluding the free flow of information and without infringing the right to obtain information. These regulations undoubtedly contribute to the sustainable development of democratic societies. The right to Informational Self-Determination constitutes an inseparable part of privacy and personal data protection and the governmental authorities must make sure that the undertaken measures guarantee also the protection of that right in this digital era.