Models of Legal Regulation of Data Protection in Canada and the USA

The article analyzes the models of legal regulation of personal data protection that have developed in the USA and Canada. The subject of the study is a comparative analysis of the legislative aspects of personal data protection in American and Canadian law. The main difference in the purpose of legal regulation is highlighted: in the United States, personal data protection is aimed at protecting a citizen from government interference, while in Canada, data protection is focused on individual autonomy through the control of personal data by the subject of such data himself. The article concludes that it is possible to use the American approach to the legal regulation of the use of personal data placed in the public domain in information and telecommunications networks.