Explores the law on rights of personality in Scotland compared to other jurisdictionsTaking a comparative perspective, this book explores the trends and issues affecting the law on rights of personality in jurisdictions drawn from the families of common law, civilian law, and mixed legal systems. The main focus is on the private law of personality rights, with due regard paid to the impact of constitutional legislation and other instruments protecting human rights.

This volume presents analyses of data protection systems and of 26 jurisdictions with data protection legislation in Africa, as well as additional selected countries without comprehensive data protection laws. In addition, it covers all sub-regional and regional data privacy policies in Africa. Apart from analysing data protection law, the book focuses on the socio-economic contexts, political settings and legal culture in which such laws developed and operate. It bases its analyses on the African legal culture and comparative international data privacy law. In Africa protection of personal data, the central preoccupation of data privacy laws, is on the policy agenda. The recently adopted African Union Cyber Security and Data Protection Convention 2014, which is the first and currently the only single treaty across the globe to address data protection outside Europe, serves as an illustration of such interest. In addition, there are data protection frameworks at sub-regional levels for West Africa, East Africa and Southern Africa. Similarly, laws on protection of personal data are increasingly being adopted at national plane. Yet despite these data privacy law reforms there is very little literature about data privacy law in Africa and its recent developments. This book fills that gap.

A new legal concept of identity. As transactions once based on personal relationships are increasingly automated, it is inevitable that our traditional concept of identity will need to be redefined. This book examines the functions and legal nature of an individual's digital identity in the context of a national identity scheme. The analysis and findings are relevant to the one proposed for the United Kingdom, to other countries which have similar schemes, and to countries like Australia which are likely to establish such a scheme in the near future. Under a national identity scheme, being asked to provide ID will become as commonplace as being asked one's name, and the concept of identity will become embedded in processes essential to the national economic and social order. The analysis reveals the emergence of a new legal concept of identity. This emergent concept and the associated individual rights, including the right to identity, potentially change the legal and commercial landscape. The author examines the implications for individuals, businesses and government against a background of identity crime.

Covers various European countries and South Africa.