May 25, 2018，The European Union’s General Data Protection Regulation officially comes into effect。The new regulations give individuals a new bet365 sign up bonus code - "the bet365 sign up bonus code to be forgotten and to erasure"，Data subjects have the bet365 sign up bonus code to request the data controller to delete personal data information，and prevent further dissemination of personal data。Most subsequent studies merge the bet365 sign up bonus code to be forgotten and the bet365 sign up bonus code to delete，Collectively referred to as the “bet365 sign up bonus code to be forgotten”。

After the proposal of the right to be forgotten, it triggered heated discussions in European and American circles and judicial circles，The most controversial point is the conflict between the right to be forgotten and the right to freedom of speech。Many legal scholars have proposed，If the right to be forgotten is strictly implemented，Individuals have the right to delete comments that are detrimental to themselves，This will inevitably impact the right to freedom of speech。How to balance the right to be forgotten and freedom of speech has become a difficult point in bet365 sign up bonus code research in the Internet era。

　　The bet365 sign up bonus code to be forgotten to protect human dignity

Jurist Robert Post believes，The right to bet365 sign up bonus code has two aspects: human dignity and personal freedom。bet365 sign up bonus code protection in Europe has always relied on the protection of human dignity。The right to be forgotten is a continuation of the European legal tradition of protecting human dignity。It was the European country that first proposed the theory of bet365 sign up bonus code rights in the world。1791，Jerome Pétion, then mayor of Paris, raised the requirement to protect citizens’ bet365 sign up bonus code when he participated in the drafting of the French constitution。Jerome admits，The right of free speech of the news media is indispensable to democratic politics，But he also sees the threat to personal bet365 sign up bonus code posed by the news media。Jerome proposed，In order to protect the precious personal freedoms won by the French Revolution from being destroyed，There is a need for legal intervention against the media’s infringement of personal bet365 sign up bonus code。

James Q. Whitman) defines the core content of European bet365 sign up bonus code rights as "an individual's right to his or her own image in public"。Protection of one’s public image was initially limited to the European aristocracy，The early famous bet365 sign up bonus code infringement cases were concentrated in the upper class，Like the Princess of Monaco、British Royal Family、French Duchess, etc.。A series of bet365 sign up bonus code infringement cases define the nature of bet365 sign up bonus code protection in Europe as personal right to honor，The connotation of rights supported by law mainly focuses on human dignity，Especially the reputation of famous public figures and nobles。The subsequent development of bet365 sign up bonus code rights in Europe gradually expanded the rights subjects from the upper class to the general public，In other words, the protection of human dignity of the people has risen to the same level as that of the nobles。Between the human dignity represented by personal bet365 sign up bonus code and the freedom of speech advocated by the democratic system，European tradition generally tends to the former。Europe’s bet365 sign up bonus code protection characteristics are influenced by Europe’s long-standing tradition of paying attention to protecting personal honor，Also related to the history of war in modern Europe。Many scholars believe that，The two world wars originating in Europe trampled on the human dignity of ordinary people，Making Europeans value personal dignity more than ever before。

The right to be forgotten also upholds the European spirit of protecting personal bet365 sign up bonus code and human dignity。The General Data Protection Regulation provides for three situations in which personal data can be deleted: The necessary data was not collected，Data information that the data subject no longer agrees to be disclosed，And other violations of EU personal information protection regulations，Such as regarding the data rights of minors, etc.。Among them，The authorization of the data subject is the key to measuring whether the data needs to be deleted。EU data protection regulations are still based on the role of personal information on personal image。For example, in the case of Google Inc. v. Gonzalez，The Court of Justice of the European Union classifies the list of relevant results searched for the keyword "name" on the Google search engine into the category of "personal information"，The court determined that the search results produced an inappropriate “personality portrait” of the information subject，And accordingly sentenced Google to delete relevant search links。In this case，The EU Court of Justice’s judgment is based on the protective effect of deleting information on human dignity，The legal significance of the right to be forgotten lies in its protection of personal integrity from infringement。

　　bet365 sign up bonus code guaranteed by the Constitution

　In 1890, Boston lawyers Warren and Brandeis attempted to introduce European bet365 sign up bonus code rights to the United States，Combat bet365 sign up bonus code violations by the news media。The United States at the end of the 19th century was a period when yellow news was rampant，Newspaper reports at that time mostly used sensationalism，A large number of eye-catching social news and crime news，Celebrity bet365 sign up bonus code becomes the object of news consumption。Warren, who comes from a prominent family, suffers from the intrusion of newspapers and photographers into his private life，But there is no way to file a legal complaint。Warren and Brandeis were dissatisfied with the laws on reputation infringement in the United States at that time。They think，U.S. law does not provide legal remedies for emotional distress caused by bet365 sign up bonus code violations，So they tried to enrich the American legal system by citing the European right to bet365 sign up bonus code theory that protects human dignity。

The development of bet365 sign up bonus code rights in the United States has not fully adopted the European personality protection approach as Warren and Brandeis hoped，American cultural genes inherit another tradition—the liberal theory of protecting freedom of speech。In the theoretical perspective of American liberalism，Government is imagined as a public institution with inherent evil，People need to beware of the abuse of government power。The media plays a social role in supervising government power，Regarded as an important guarantee of American democracy。In the eyes of liberals，Government is the enemy of civil liberties，The public needs to unite with the media to fight against the government，Preventing corruption and deterioration of public power。Media freedom is the foundation for the founders of the United States to build a free social structure，Jefferson regarded a free press as the foundation of a democratic society。The First Amendment to the U.S. Federal Constitution embodies the theoretical vision of American liberalism，Protecting freedom of speech is the ethos of American law that is different from that of Europe。

Political preferences that protect freedom of speech under the U.S. Constitution often conflict with the need for legal remedies for bet365 sign up bonus code infringement。In bet365 sign up bonus code infringement cases，U.S. courts generally tend to support freedom of expression，Instead of protecting individual human dignity，Because the former has social value protected by the U.S. Constitution。In the determination of specific cases，The court’s basis for judgment is often “news value”，Instead of personal dignity。In the widely cited "Florida Star Case"，Newspaper reveals victim’s real name when reporting rape case，Florida District Court rules bet365 sign up bonus code infringement established，The U.S. Supreme Court overturned the district court’s decision on the grounds that the case involved public interest。The Supreme Court’s decision follows the tradition of liberal press freedom。In this tradition，News value based on professionalism is a technical tool for the media to perform its liberal guarantee function。When it comes to the public’s interest in knowing，The value of news is usually greater than the value of personal bet365 sign up bonus code protection。

　The balance between freedom of speech and bet365 sign up bonus code protection

In the Internet era，The United States has extended its legal tendency to protect free speech to Internet service providers with some media properties，Europe continues to maintain the tradition of attaching importance to human dignity and personal bet365 sign up bonus code protection。The differences in bet365 sign up bonus code culture between Europe and the United States have triggered many debates，This also triggered conflicts in relevant legal judgments、International trade friction and cross-cultural value collision。In Germany，Microsoft is being sued for failing to prevent fake nude photos of tennis stars from being circulated online。French model sues website that stored her nude images，causing the website to go bankrupt。And in the United States，Similar lawsuits do not always achieve results that uphold individual bet365 sign up bonus code rights。The U.S. Congress passed laws in the early stages of the development of the Internet，Prohibition on imposing liability on network service providers。The same is the spread of nude photos，The party’s request for a dissemination ban was rejected by the U.S. court on the grounds that the photo was widely available on the Internet and therefore not actionable。

When weighing bet365 sign up bonus code rights and free speech，The United States also has cases supporting bet365 sign up bonus code protection。In U.S. Department of Justice v. Reporters Committee for Freedom of the Press，CBS requested the FBI to release personal criminal records in its possession in accordance with the Freedom of Information Act。While CBS and the Reporters Committee for Freedom of the Press sued on the grounds that information about the criminal's history was in the public interest，The court still made a judgment to protect the criminal’s personal bet365 sign up bonus code。However，There are only a handful of cases in U.S. judicial practice that place bet365 sign up bonus code rights above freedom of speech，And the burden of proof determined by the court is on the injured party。The right to be forgotten establishes a new burden of proof - those who spread information need to self-certify the legitimacy of their speech and information，That is, no infringement of personal bet365 sign up bonus code information。

The discord between Europe and the United States over the right to be forgotten stems from their different liberal traditions，Europe focuses on personal freedom and individual dignity，The United States prefers freedom of speech and market economy。The United States views Europe’s right to be forgotten as a forced export of European values，The United States’ preference for Internet giants is characterized by Europeans as a profit-seeking economic priority。Mediating legal disputes arising from the right to be forgotten，First of all, it is necessary to weigh the priority between the protection of personal bet365 sign up bonus code rights and freedom of access to information in the information society。Secondly，To balance the tension between material orientation and humanistic spirit。The development of digital economy provides impetus for technological upgrading，The "right to be forgotten" retains the human touch for the social structure under technological discipline。How to reasonably regulate the media attributes of the Internet without inhibiting network innovation，This requires the cooperation of two liberal traditions。

　(Author’s unit: Institute of Journalism and Communication, Chinese Academy of bet365 sign up bonus code Sciences)