The transnational dimension of data protection: comparative perspectives from digital constitutionalism

This article aims to analyse how the consolidation of the European constitutional system of privacy and personal data has contributed to building a transnational model in the digital age. By adopting a comparative perspective, this work aims to underline how the European approach has created bridges across the Atlantic, providing an opportunity to examine different expressions of digital constitutionalism. The first part underlines the consolidation of the protection of personal data in the European constitutional framework. The second part analyses the extension of the European model across the Atlantic, looking at the extraterritoriality, global delisting, and transfer of data. The third part examines the transatlantic challenges for constitutional democracies as global regulators in the algorithmic society.