PRIVACY PROTECTION FROM THE PERSPECTIVE OF SINO-US COMPARISON

The present study discusses the privacy Protection from the Perspective of Sino-US Comparison. The system of privacy right originates from American law, which is closely related to the American lifestyle, national psychology and other factors. The system of privacy right in Chinese law originates from the legal succession of the late Qing Dynasty. After the draft of the civil law, it finally took shape in the civil code in the Republican period. Since the founding of New China, the ways and means of protecting privacy right have been changing. Because of the differences between Chinese people's national psychology, lifestyle and Western countries, the system of privacy right has different connotations in China and its own characteristics in practice. In the process of compiling the current Civil Code, the protection of privacy right should be formally confirmed in the legislation of personality right, and its protection mode should return to the law of confirming the connotation of the right, rather than simply reverse regulation from the perspective of infringement.