The Right To Be Forgotten In The Digital Age: A Comparative Legal Analysis Of The European Model (Gdpr) And National Approaches Of Post-Soviet States

Abstract

The right to be forgotten or the right to erasure has emerged as one of the most contested and consequential doctrines in contemporary digital law. Codified in Article 17 of the European Union’s General Data Protection Regulation (GDPR), this right empowers individuals to demand the deletion of personal data under specific circumstances, balancing privacy interests against freedom of information and public memory. This article undertakes a comparative legal analysis of the GDPR framework and the legislative responses of selected post-Soviet states, including Russia, Kazakhstan, Ukraine, and Uzbekistan. Drawing on statutory texts, judicial decisions, and doctrinal commentary, the study identifies convergences and divergences in the conceptualization, scope, and enforcement of the right to be forgotten across these jurisdictions.