Legal Framework for Privacy Protection in the Digital Context: A Comparative Study in the Legal Systems of the United States, the European :union:, and Iran

Shojaei, Abdolsaeed; Rahmani, Shahram

doi:10.48311/clr.2025.101678.0

Legal Framework for Privacy Protection in the Digital Context: A Comparative Study in the Legal Systems of the United States, the European :union:, and Iran

Articles in Press

Document Type : مقالات علمی پژوهشی

Authors

abdolsaeed shojaei

shahram rahmani

Faculty member of Payam Noor University

10.48311/clr.2025.101678.0

Abstract

The emergence of social media, artificial intelligence, and the Internet of Things has enabled the widespread collection of personal data by government and private entities, reducing individuals' control over their information. In the United States, the legal framework for privacy is based on laws such as the Privacy Act of 1974 and COPPA, which emphasize self-regulation and the role of the private sector. However, due to the lack of coordination between laws and heavy reliance on voluntary regulations, it faces implementation problems. In contrast, the European Union, with its General Data Protection Regulation (GDPR), has provided a comprehensive and strict system based on principles such as transparency, consent, and the right to be forgotten.

Keywords

Privacy

cyberspace

General Data Protection Regulation (GDPR)

Computer Crime Law

Personal Data Protection in Iran

Subjects