right to be forgotten

The New York Times' Farhad Manjoo writes that the right to be forgotten--or, more specifically, the right requiring search engines to erase the online search results about European citizens in favor of their privacy--could spread to the United States. For example, a French regulator has ruled that all of Google's sites, including American versions, should grant the right to be forgotten on Google sites that are not country specific.

The United States and Europe, which have consensus on what constitutes copyrighted content, do not have the same consensus on what should be private information, Manjoo writes. But the law on which the right to be forgotten in Europe is based has no territorial restrictions.

The "right to be forgotten" has arrived in Asia. According to a report in the Associated Press, a Japansese court has ordered Google to remove search results that "hinted at the man's relations with a criminal organization after he complained his privacy rights were violated."

Europe's highest court made a similar ruling in May; some lawyers say the ruling could lead to the exportation of Europe's privacy laws to the rest of the world.