LEGISLATION IN THE FIELD OF PERSONAL DATA PROTECTION IN THE DIGITAL ENVIRONMENT: FOREIGN EXPERIENCE AND NATIONAL PERSPECTIVES

This article provides a comparative legal analysis of the experience of various foreign countries in ensuring the protection of personal data as a fundamental human right in the context of digital transformation. The study compares the approaches to ensuring the right to privacy, the rights of the data subject, and human rights in the digital environment in the national legislative systems of the European Union, the United States of America, the Asia-Pacific region, and Central Asia. The article reveals the specific features of the models of regulation of digital rights and institutional systems of states belonging to different legal families. The author used the methodology of comparative analysis to determine the most effective ways of implementing international human rights standards into national legislation. The research results will serve to develop practical recommendations for improving the system of human rights protection in the digital environment of the Republic of Uzbekistan.

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