Some concepts of legal protection of data subject first guaranteed by the Council of Europe Convention for the Protection of Individuals with Regard to Automatic Processing of Personal Data ("Convention 108") in 1981. However, the Convention 108 lacked to stipulate rights of a data subject. Directive 95/46/EC of the European Parliament and of the Council of the European Union that was approved on 24 October 1995 has secured two particular rights of data subject, which are right of access to data and right to object data processing. Regulation (EU) 2016/679 of the European Parliament and of the Council, which guarantees all rights of the data subject in European Union was adopted on 27 April 2016.
However, these rights of data subject that secured through above regulations are only applicable to the European Union, not to other countries. This article aims to identify the rights of data subjects in non-EU countries by thoroughly examining national legislations of such countries and compare them to the European Union. Based on the examination, the article attempts to propose potential ways of ensuring rights of the data subject in non-EU countries.
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