2023 KGRI Working Papers
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Comparative Law Research on the Personal Data Protection Law in Various Countries
No.1 Tatsuhiko Yamamoto, Kyoichi Iida, Taiki Sato
November, 2023
The aim of "Decentralized Management and Law" (Principal Investigator: Prof. Tatsuhiko Yamamoto, Professor of Constitutional Law at Keio Law School), which is a part of the Moonshot R&D Program (Goal 9) by Japan Science and Technology Agency (JST), is to analyze the benefits and challenges of implementing personal AI in society from legal perspective. Personal AI is Artificial Intelligence that assists individual in management of his or her personal data, based on their privacy preference. This tool is expected to back up the right to informational self-determination or the right to control personal information.
In this research project, we analyze personal data protection laws from comparative law perspective in various countries such as the EU, Germany, France, Switzerland, the United States, Canada, South Korea, Taiwan, Thailand, and China. We asked legal scholars from those countries to write reports on the right of data subjects to control their personal data, such as the right to erasure, access, and data portability. We considered the implications and challenges of the right to informational self-determination, focusing on the relationship between constitutional law and personal data protection laws.
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