Front Matter -- Copyright -- Contents -- Contributors -- Preface -- 1. Introduction -- PART I THEORETICAL CONSIDERATIONS -- 2. The origins and development of the right to privacy -- 3. Privacy and incrementalism -- 4. Theories of reputation -- 5. Separated by a common language: the antipaternalism principle in US and English defamation and privacy law -- PART II PRIVACY LAWS COMPARED -- 6. Weighing content: can expression be more or less important? Categorical or case by case balancing and its (respective) disposition to rank relevance of communication 7. What is it the public has a right to know? The right to privacy for public officials and the right of access to official documents -- European and Swedish perspectives -- 8. Do we need to separate privacy and reputation? USA, Europe and Korea compared -- 9. Public image (un)limited: privacy rights of the photographic subject in England and New York compared -- 10. What newsworthiness means -- 11. Defamation by photo manipulation under New Zealand law -- PART III DATA PROTECTION -- 12. A European and German perspective on data protection law in a digitised world 13. Right to be forgotten in the global information economy -- 14. Enforcing privacy through individual data access rights: a comparative study -- PART IV DEFAMATION LAWS COMPARED -- 15. Defamation: a half-century of changes (more or less) -- 16. A comparative analysis of the treatment of corporate reputation in Australia and the UK -- PART V DEFAMATION, PRIVACY AND NEW TECHNOLOGIES -- 17. Liability of internet intermediaries for defamation: beyond publication and innocent dissemination -- 18. Defamation on the internet: the role and responsibilities of gatekeepers 19. Privacy, remedies and comity: the emerging problem of global injunctions and some preliminary thoughts on how best to address it -- PART VI COUNTRY CHAPTERS -- 20. Free speech and the rights relating to personality involving politicians in French law -- 21. Italian defamation and privacy law from a comparative perspective -- 22. Canadian defamation and privacy law in comparative context -- 23. Privacy and defamation in Australia -- a post-colonial tango -- 24. South Africa's reasonable publication defence and the United Kingdom's public interest defence: two sides of the same coin? 25. Defamation and privacy law in Japan -- from a comparative perspective -- 26. The Chinese defamation law four decades on (1979-2019): legal rules versus political uncertainties -- Index
Summary:
Providing comparative analysis that examines both Western and non-Western legal systems, this wide-ranging Handbook expands and enriches the existing privacy and defamation law literature and addresses the fundamental issues facing today's scholars and practitioners. Comparative Privacy and Defamation provides insightful commentary on issues of theory and doctrine, including the challenges of General Data Protection Regulations (GDPR) and the impact of new technologies on the law. Chapters explore the origins and development of the right to privacy, privacy rights of photographic subjects and defamation by photo-manipulation, and the right to be forgotten. Containing contributions from expert international scholars, this comprehensive Handbook investigates the liability of internet intermediaries in cases of defamation and the emerging problem of global injunctions before concluding with eight country focussed studies. Engaging and accessible, this Handbook will be a key resource for students and scholars researching in the fields of privacy and defamation law, internet and technological law and information and media law" Provided by publisher.
This resource is supported by the Institute of Museum and Library Services under the provisions of the Library Services and Technology Act as administered by State Library of Iowa.