The different right to privacy for private citizens, public figures and civil servants

This paper examines the differentiated application of the right to privacy concerning private citizens, public figures, and civil servants within contemporary legal and journalistic contexts. Synthesizing existing scholarship and case law primarily from the United States and Europe (including ECHR jurisprudence), it analyzes the patterns and contradictions inherent in balancing privacy expectations against the principles of free expression and the public's right to know. While private individuals generally retain robust privacy protections, public figures and officials experience diminished expectations, particularly when their actions intersect with legitimate public interest. However, the analysis reveals inconsistencies in defining "public interest" and the adequacy of protections against unwarranted intrusion, especially in the digital age. Key case studies illustrate the divergent approaches, highlighting the U.S. emphasis on newsworthiness versus the European focus on proportionality and human dignity. The paper identifies gaps in addressing the privacy challenges posed by technology and globalization, concluding that while legal frameworks vary, the concept of justifiable public interest remains a central, albeit contested, arbiter in mediating the tension between privacy and transparency. Ethical considerations in journalism often provide a crucial, though non-binding, layer of restraint.