The article presents a comprehensive study of the administrative and legal foundations of personal data protection through the lens of a comparative analysis of leading international regulatory models in this field. The relevance of the study stems from the rapid development of information technologies and the digitalisation of social relations, which underscores the importance of administrative and legal regulation of personal data protection as a key component of ensuring information security and safeguarding citizens’ rights in the digital environment. This issue is particularly pressing in the context of Ukraine’s European integration ambitions and the need to align national legislation with international standards for data protection. The article examines the constitutional and legal approach to defining personal data as an integral part of fundamental human rights, particularly the right to privacy, dignity, and self-realisation in the information sphere. It substantiates the need to enshrine the right to personal data protection in Ukraine’s Constitution, either by amending Article 32 or by introducing a separate provision on individual information rights. A detailed analysis is provided of the European model of personal data protection, embodied in the General Data Protection Regulation (GDPR), which is based on the principles of safeguarding fundamental human rights and maintaining high standards of privacy. The extraterritorial nature of this model and its influence on the development of global data protection standards are highlighted. The article also explores the U.S. regulatory system, which is characterised by a utilitarian approach focused on economic expediency and market principles, with an emphasis on sectoral regulation and business self-regulation. Particular attention is given to the California Consumer Privacy Act (CCPA) as a significant step towards aligning U.S. standards with European data protection requirements. The article argues in favour of developing a hybrid administrative and legal model for Ukraine, combining European standards for the protection of individual rights with flexible mechanisms adapted to national specificities and the dynamic evolution of digital technologies.
O. V. Solodovnik (Thu,) studied this question.