抄録
This article analyzes and compares the Japanese and European debates on how to conceptualize the fundamental rights protection of data subjects with regard to the handling of personal data and information. In Japan, the right to control one’s own information, which has been recognized since the 1970s, has expanded and changed through several stages of development. In the current debate, it has been suggested that the right to appropriate handling of personal information should be at the heart of the fundamental rights protection. In some member states of the European Union, certain individual rights have also developed since the 1970s, in particular the right to informational self-determination in Germany. Meanwhile, the Charter of Fundamental Rights of the European Union enshrines a right to the protection of personal data. This fundamental right needs to be specified in a unique way in terms of content and doctrine. The results of the article include the thesis that the protection of fundamental rights with regard to personal data and information should no longer be understood primarily through the lens of the control paradigm. Instead, a multi-layered, multi-dimensional, and multi-faceted concept needs to be elaborated, which calls for overarching regulatory mechanisms as well as individual rights.
https://ror.org/00g30e956 
