The Right to be Forgotten in the Digital Age: A Comparative Analysis of Legal Practice in the EU, USA, Russia, And Uzbekistan
Abstract
This article provides a comprehensive examination of the right to be forgotten, comparing its legal foundations, interpretations, and enforcement across four jurisdictions: the European Union, the United States, the Russian Federation, and the Republic of Uzbekistan. It explores how cultural values, constitutional principles, and political environments shape the practical scope of data-erasure provisions and delisting requests in each setting. Through a comparative legal methodology, the research draws on statutes, court rulings, academic publications, and advocacy group reports to illustrate the delicate balance between privacy protection and freedom of expression. The analysis gives particular attention to the General Data Protection Regulation in the European Union, state-level privacy laws in the United States, legislative amendments in Russia, and evolving data-protection norms in Uzbekistan. Key findings highlight the influence of differing legal cultures, institutional structures, and enforcement mechanisms on the efficacy of the right to be forgotten, while also addressing the potential misuse of erasure requests to stifle public-interest information. The article concludes by considering prospects for cross-border cooperation and the continued evolution of data-protection frameworks amid rapidly changing technologies.