COMPARISON AND VALUE: CONSIDERING THE MODEL RIGHT TO DATA ERASURE

A modern extension from the data protection right to privacy, the Right to Erasure makes a world of difference in the online environment through its function to delete. Promoting the essence for a curb to access information freely whilst emergent technologies thrive in environments yet to feel the necessity for legal regulation and thereby permitting frictionless data usurpation. Central assessment concerning the right to data erasure (happens) with a focus from the internet users perspective – tracing its most advanced form in Europe by assessing its application through the framework for personal health data, firstly, and subsequently comparing the EU legislation’s legal provision with what obtains across Africa, California, USA and Nicaragua – thereby evidencing that after the General Data Protection Regulation, the Californian provision is more economically viable as a legal tool to that concerning Africa, after which (restrictive) Nicaragua follows in ranking for a universal right. The thesis explores the legal provisions for the data erasure right through normative economic analysis. Through a Doctrinal law in context comparative, a critical assessment concerning the possibility for a worldwide right to request for data erasure on a residence basis is conducted through databases. The findings are rationally ascertainable by having regard to terminological definitions, the theoretical exercise of the RtE, and cost benefit valuation given the legal origins within the respective (aforementioned) legal systems, sphere and theoretical implementation cost. Above all else, highlighting the need why reimagining the way personal data is useful for first person, and for third party access resonates an important transnational issue for the next future.