Cookies Policy

This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies.

I accept this policy

Find out more here

The Right to Be Forgotten and What the Laws Should/Can/Will Be: Comparing the United States and Canada

No metrics data to plot.
The attempt to load metrics for this article has failed.
The attempt to plot a graph for these metrics has failed.
The full text of this article is not currently available.

Brill’s MyBook program is exclusively available on BrillOnline Books and Journals. Students and scholars affiliated with an institution that has purchased a Brill E-Book on the BrillOnline platform automatically have access to the MyBook option for the title(s) acquired by the Library. Brill MyBook is a print-on-demand paperback copy which is sold at a favorably uniform low price.

Access this article

+ Tax (if applicable)
Add to Favorites
You must be logged in to use this functionality

image of Global Journal of Comparative Law

This article will first examine why the right to be forgotten should be recognized as a universal right by drawing upon natural law theories. Using the recent decision by the European Court of Justice as a starting point, it will then explore whether this right can be recognized in the United States and Canada. Often held to be similar in terms of cultures and values, the two neighbors in fact have very different free speech and privacy traditions. This article will conduct a comparative study of the U.S. and Canada to explain why this right can be accommodated by their laws and traditions from a theoretical perspective. Finally, it will adopt the framework of judicial globalization to explore why and to what extent the right to be forgotten will be recognized in these two jurisdictions.

Affiliations: 1: University of British Columbia,


Full text loading...


Data & Media loading...

Article metrics loading...



Can't access your account?
  • Tools

  • Add to Favorites
  • Printable version
  • Email this page
  • Subscribe to ToC alert
  • Get permissions
  • Recommend to your library

    You must fill out fields marked with: *

    Librarian details
    Your details
    Why are you recommending this title?
    Select reason:
    Global Journal of Comparative Law — Recommend this title to your library
  • Export citations
  • Key

  • Full access
  • Open Access
  • Partial/No accessInformation