A Comparative Study of Right To Privacy In UK USA and India With A Special Reference To Data Protection

Abstract

the Privacy Act, of 1974, and the UK is governed by the 1995 General Data Protection Regulations, they are not comprehensive and have limited application. And in India, the Information Technology Act, 2000 with the amendments in 2008 has few provisions that have bearing on the privacy and data protection aspects. However, to some extent, the judicial verdicts in all three jurisdictions have recognized the right to privacy as a fundamental right. newline