PERSONAL DATA SOVEREIGNTY IN THE DIGITAL AGE: A COMPARATIVE ANALYSIS OF GLOBAL AND DOMESTIC REGULATORY FRAMEWORKS

Abstract

In today's society, the number of companies collecting and processing personal data is growing, which poses a threat to the security of confidentiality and the security of the human right to privacy. That is why the role of legislative regulation of data privacy protection is growing. The study aimed to compare domestic legislative documents with European and American norms in personal data protection and to identify trends in the country's legal regulation of data privacy. It used bibliographic, induction-deduction, quantitative-comparative, trend, comparative-logical and graphical methods to achieve this goal. The results revealed the need to improve regulatory documents on personal data protection, especially for users of Internet resources. The problem of regulations exists in both Ukrainian and international law. The study has revealed similarities between the basic principles of the Law of Ukraine and the GDPR, but the liability in Ukraine is less than in Europe. A growing trend has been identified: in recent years, the number of court decisions on violations of personal data protection has increased significantly, and according to statistical forecasts, it will continue to grow. At the same time, the structure of court decisions showed that administrative, civil and criminal decisions predominate among the decisions. Hence, most cases relate to disseminating and processing data by public services.