LEGAL CONCEPTS OF CROSS-BORDER DATA PROTECTION IN UZBEKISTAN
Authors
Shakhnoza Ibragimova ()Files
Abstract
This article examines the principal theoretical concepts underpinning the legal regulation of cross-border data flows, grouping them into three currents: the statist approach rooted in territorial sovereignty, the liberal-rights approach centred on fundamental rights, and technical normativism. Through comparative analysis of data protection legislation across the CIS states, the study identifies two competing regulatory models — the primacy of state control and liberal-rights integration — and situates Uzbekistan within this framework. Particular attention is given to the jurisprudence of the Court of Justice of the European Union on the right to erasure and adequacy, which reveals an unresolved tension between territoriality and universality. The article concludes that the dual character of personal data, simultaneously a constitutionally protected personal good and an object of economic circulation, constitutes the central theoretical problem of cross-border data law.
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