UK moves towards stringent European laws
PRIVACY laws in Britain are moving closer to the more stringent rules in Europe after a High Court judge ruled in favour of Sir Cliff Richard.
France and Germany have some of the most restrictive press regulations on the continent, where there is a stronger tradition of privacy.
French laws, for example, ban the publication both of details of a person’s private life and the “theft of personal image”, technically banning taking photographs without consent. The laws have allowed several high-profile politicians to keep secret details of their private lives which would have made front page news in the UK.
Details of François Mitterrand’s second family and daughter were only published with the former president’s permission shortly before his death.
In the US, the principle of freedom of expression is enshrined in the constitution, which experts say gives the media greater freedoms.
News organisations will be protected against a privacy claim if they can show that a story about a public figure was “newsworthy”.
Privacy laws have created difficulty for judges in the internet age. There has been criticism of gags on the UK press in cases where the identities of those involved are widely available online.
The Supreme Court in 2016 upheld an injunction banning the naming of a married star who had a threesome despite his identity being published in both the US and Scotland, where the injunction did not apply.