2007Journal of Yangtze UniversityRequires access

Privacy Protection in Comparative Law

Tang Xiao-ling

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Abstract

There are differences between the two legal system in legislation on privacy protection.In common law system specific law is adopted,and in civil law system privacy is treated as an personality right in civil code.Different patten causes different effect.

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What this paper is about

There are differences between the two legal system in legislation on privacy protection.In common law system specific law is adopted,and in civil law system privacy is treated as an personality right in civil code.Different patten causes different effect.

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Available abstract

There are differences between the two legal system in legislation on privacy protection.In common law system specific law is adopted,and in civil law system privacy is treated as an personality right in civil code.Different patten causes different effect.

Key concepts: Legislation, Privacy law, Data Protection Act 1998, Civil law (Civil law), Law, Information privacy, Information privacy law, Privacy protection

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