In what circumstances it is likely that article 8 of the European convention of human rights will be used successfully to protect privacy. Illustrate &explain
The Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR) was adopted under the auspices of the Council of Europe in 1950 and entered into force in September 1953. The human rights that are enshrined within the ECHR are enforceable in the UK’s domestic courts by virtue of the Human Rights Act 1998.
Article 8 ECHR constitutes what is known as a ‘qualified right’. This means that state interference with the rights set out under Article 8 is permissible in certain specific situations. It is immediately obvious that Article 8 is divided into two parts. The first part, Article 8 (1) sets out the precise rights which are to be guaranteed to an individual by the State – the right to respect for private life, family life, home and correspondence. The second part, Article 8 (2) makes it clear that those rights are not absolute in that it may be acceptable for public authorities to interfere with the Article 8 rights in certain circumstances. Article 8 (2) also indicate the circumstances in which public authorities can validly interfere with the rights set out in Article 8 (1) only interferences which are in accordance with law and necessary in a democratic society in pursuit of one or more of the legitimate aims listed in Article 8 (2) will be considered to be an acceptable limitation by the State of an individual’s Article 8 rights.
Private life includes an individual’s physical and psychological integrity, personal or private space, the collection and publication of personal information, personal identity, personal autonomy and sexuality, self development, relation with others and reputation. Article 8 also provides a framework for monitoring the gathering and retention of personal data. It is designed to ensure that the right to keep personal data from being disclosed to third parties can be balanced against legitimate aims of a democracy, such as crime prevention or the economic wellbeing of society. Types of data that would fall within the scope of Article 8(1) include census information and ID schemes. Most forms of surveillance will constitute an interference with the right to a private life. This includes the use of CCTV, phone-tapping, the installation of listening devices in the workplace and home, and surveillance via GPS. The digital recording of a public scene, for example by CCTV, can give rise to Article 8 considerations.
The concept of family life goes beyond formal or traditional relationships. It covers engaged couples, cohabiting couples and same-sex couples.3 It also covers relationships with siblings, foster parents and foster children and grandparents and grandchildren.  In Britain, Article 8 issues arise frequently in the context of immigrants and asylum seekers. It is generally accepted that Article 8 may be engaged by an interference with family ties in Britain, but immigration control is usually cited as a legitimate reason under Article 8(2) for the interference.  The issue in dispute is generally the proportionality of the interference. So, for example, case law suggests that it will rarely be proportionate to order removal for immigration purposes of a spouse to a country that the other spouse cannot reasonably be expected to reside in. Nor may it be proportionate to sever a genuine and subsisting relationship between parent and child. In deportation cases of non-British citizens who have committed a serious crime it is still necessary to draw the balance of proportionality under Article 8.7 Extradition in accordance with an extradition treaty is a proportionate interference with Article 8(1), save for in exceptional circumstances.
The right to privacy can only be limited by law when it is necessary to do so in a democratic society for reasons such as national security, public safety, the prevention of crime or protection of the rights and freedoms of others. Any limitation on this right must be proportionate.
The importances of the right to personal privacy become self-evident in the immediate aftermath of the horrors of the Second World War. The right to a private life is based on principles of human dignity and is inherently linked to many other rights such as equal treatment and free expression. A society that does not pay proper regard to personal privacy is one where dignity, autonomy and trust are fatally undermined.
Respect for correspondence
Everyone has the right to uninterrupted and uncensored communication with others – a right particularly of relevance in relation to phone-tapping; email surveillance; and the reading of letters.
Article 8 is a qualified right and as such the right to a private and family life and respect for the home and correspondence may be limited. So while the right to privacy is engaged in a wide number of situations, the right may be lawfully limited. Any limitation must have regard to the fair balance that has to be struck between the competing interests of the individual and of the community as a whole.
In particular any limitation must be:
- in accordance with law;
- necessary and proportionate; and
- for one or more of the following legitimate aims:
· the interests of national security;
· the interests of public safety or the economic well-being of the country;
· the prevention of disorder or crime;
· the protection of health or morals; or
· the protection of the rights and freedoms of others.
What rights does the Human Rights Act protect
- The right to life – protects your life, by law. The state is required to investigate suspicious deaths and deaths in custody.
- The prohibition of torture and inhuman treatment – you should never be tortured or treated in an inhuman or degrading way, no matter what the situation.
- Protection against slavery and forced labour – you should not be treated like a slave or subjected to forced labour.
- The right to liberty and freedom – you have the right to be free and the state can only imprison you with very good reason – for example, if you are convicted of a crime.
- The right to a fair trial and no punishment without law – you are innocent until proven guilty. If accused of a crime, you have the right to hear the evidence against you, in a court of law.
- Respect for privacy and family life and the right to marry – protects against unnecessary surveillance or intrusion into your life. You have the right to marry and raise a family.
- Freedom of thought, religion and belief – you can believe what you like and practise your religion or beliefs.
- Free speech and peaceful protest – you have a right to speak freely and join with others peacefully, to express your views.
- No discrimination – everyone’s rights are equal. You should not be treated unfairly – because, for example, of your gender, race, sexuality, religion or age.
- Protection of property, the right to an education and the right to free elections – protects against state interference with your possessions; means that no child can be denied an education and those elections must be free and fair.
The HRA provides that the human rights contained in the European Convention on Human Rights form part of UK law in three ways:
1) All UK law must be interpreted, so far as it is possible to do so, in a way that is compatible with HRA rights.
2) If an Act of Parliament breaches these rights the courts can declare the legislation to be incompatible with rights. This does not affect the validity of the law – the HRA maintains parliamentary sovereignty as it remains up to Parliament to decide whether or not to amend the law.
3) It is unlawful for any public authority to act incompatibly with human rights (unless under a statutory duty to act in that way), and anyone whose rights have been violated can bring court proceedings against the public authority.
Obligations of Article 8
Article 8 imposes two types of obligations on the state and public authorities:
• Negative obligation not to interfere with an individual’s private life, family life, home and correspondence.
• Positive obligation to take steps to ensure effective respect for private and family life, home and correspondence, between the state and the individual, the individual and private bodies, and between private individuals through law enforcement, legal and regulatory frameworks and the provision of resources.
The development of Article 8 in UK
Before the Human Rights Act 1998 (HRA) was enacted, there was no explicit right to privacy in English law. Instead, remedies for breaches of particular privacy interests have relied on certain aspects of the common law. For example, a person’s reputation and confidential information were protected by the defamation and confidentiality laws; personal and property interests by the law of trespass.
By incorporating Article 8 into UK law, the HRA changed how privacy is viewed and valued in the UK. It has led to increased protection for the right to private and family life, and imposed obligations on the state to protect and promote Article 8.  For example, the Regulation of Investigatory Powers Act 2000 provides protection from infringements of privacy relating to personal data and surveillance.
How Article 8 protects privacy
There are many aspects to privacy. We discuss issues of privacy and media freedom under Article 10, freedom of expression. This chapter focuses on information privacy, which concerns the collection, use, tracking, retention and disclosure of personal information. Subject to limited exceptions, Article 8 protects an individual’s right not to have personal information or data disclosed to third parties without their consent. This means that people generally have the right to determine who has access to personal data about themselves, and what the data will be used for. The legal principle is that: ‘all information about a person is in a fundamental way his own, for him to communicate or retain for himself as he sees fit’. Any data processing and surveillance by the state is likely to engage Article 8. Because Article 8 is a qualified right, however, such activity will not breach Article 8 if it can be justified under one of the requirements listed in Article 8(2). However, the state has a positive obligation under Article 8 to protect individuals from breaches by third parties in some circumstances, for example through domestic laws and regulation. There are still a number of issues relating to surveillance and information privacy that pose particular challenges for the state in meeting its Article 8 obligations. To some extent, this is due to the complexity of Article 8(2) itself, and the difficulties that the UK courts, the European Court of Justice and the European Court of Human Rights have had in providing clear guidance on the meaning and scope of the terms.
Over the last few decades, developments in technology have led to a rapid expansion of surveillance and data collection techniques that enable public authorities and private companies to collect, retain and access and share a huge amount of personal information about people going about their daily lives. In 2011 the Commission published an important report by Charles Raab and Benjamin Goold on information privacy that raised questions about how well our personal information is protected given the extent to which data collection and surveillance permeates the lives of individuals in the UK today. For example, there is an extensive network of at least 1.8 million CCTV cameras trained on everything from roads to schools to shopping centers; an estimated 80 million active mobile phone subscriptions allow companies to collect data on the location of subscribers at any time; and electronic travel passes, such as the Oyster card used in London, collect data on the travel patterns of millions of individuals. The Joint Committee on Human Rights (JCHR) has pointed out that the collection and sharing of data is not objectionable in itself.  There are undoubted benefits to the use of data sharing and surveillance techniques to prevent and fight crime and protect national security. Public authorities are often required to share data (or enable others to do so) for administrative purposes, for example taxation, or in meeting other obligations such as protecting the right to life. Many pieces of legislation permit data to be collected for different purposes. The JCHR reviewed the data protection provisions in 2008. It found that 17 pieces of legislation provided inadequate protection for personal data.
In 2004 the Information Commissioner, Richard Thomas, warned that Britain would ‘sleep-walk into a surveillance society’, in response to the government’s plans to introduce ID cards and an accompanying National Identity Register. The scheme, introduced under the Identity Act 2006, has now been scrapped by the Coalition Government as part of its pledge to protect civil liberties. However, many changes to the ways in which personal data is collected and shared continue to come about with minimal or no scrutiny, although there are signs that the tide might be turning amid increasing public concern over information privacy issues.
“Not every act or measure which adversely affects moral or physical integrity will interfere with the right to respect to private life guaranteed by Article 8. However, the Court’s case law does not exclude that treatment which does not reach the severity of Article 3 treatment may nonetheless breach Article 8 in its private life aspect where there are sufficiently adverse affects on physical and moral integrity. Private life is a broad term not susceptible to exhaustive definition. The Court has already held that elements such as gender identification, name and sexual orientation and sexual life are important elements of the personal sphere protected by Article 8. Mental health must also be regarded as a crucial part of private life associated with the aspect of moral integrity. Article 8 protects a right to identity and personal development, and the right to establish and develop relationships with other human beings and the outside world. The preservation of mental stability is in that context an indispensable precondition to effective enjoyment of the right to respect for private life…. Even assuming that the dislocation caused to the applicant by removal from the United Kingdom where he has lived for the last 11 years was to be considered by itself as affecting his private life, in the context of the relationships and support framework which he enjoyed there, the Court considers that such interference may be regarded as complying with the requirements of the second paragraph of Article 8, namely as a measure “in accordance with the law”, pursuing the aims of the protection of the economic well being of the country and the prevention of disorder and crime, as well as being “necessary in a democratic society” for those aims.” (The Strasbourg court’s opinion in Bensaid v UK (2001) 33 EHRR 10 was that).
There are some real life cases given below to show that how Article 8 of ECHR works-
· A young man called Graham Gaskin was very badly treated in care for many years. He wanted to read his social services files, which were kept by Liverpool City Council. The Council refused to let him see all his files. Graham Gaskin went through the courts in the UK to try and force the Council to let him see his files, but the courts agreed with the Council. So he took his complaint to the European Court of Human Rights.
The European Court of Human Rights said the Council had breached Graham Gaskin’s rights. The Court agreed he needed to see his social services files in order to try and make sense of his childhood and his treatment in care. As a result of Graham Gaskin’s complaint, which was decided by the European Court in 1989, it is now much easier for people in care or in contact with social services to see information that is written about them. Councils must now keep files concerning children in care for 75 years. 
· Two children and an adult got help from lawyers to complain about the police. They had been stopped and searched by the police while at a protest in Kent about protecting the environment. The children were told that they were being searched for items because they were going to the protest. They were frightened by the experience. They complained to the UK courts, but before the case finished the police agreed they had breached the children’s rights. A settlement was agreed and each child received compensation of £1,125 and a personal apology from the police. A letter was also sent to every UK police force explaining why ‘stop and searches’ that are carried out disproportionately are against the law and what should be done differently in future. 
Cases related to Article 8
· In the House of Lords case of Razgar, Lord Bingham said the following about the nature of private life (paragraph 9):
‘This judgment establishes, in my opinion quite clearly, that reliance may in principle be placed on article 8 to resist an expulsion decision, even where the main emphasis is not on the severance of family and social ties which the applicant has enjoyed in the expelling country but on the consequences for his mental health of removal to the receiving country. The threshold of successful reliance is high, but if the facts are strong enough articles 8 may in principle be invoked. It is plain that “private life” is a broad term, and the Court has wisely eschewed any attempt to define it comprehensively. It is relevant for present purposes that the Court saw mental stability as an indispensable precondition to effective enjoyment of the right to respect for private life. In Pretty v United Kingdom (2002) 35 EHRR 1, paragraph 61, the Court held the expression to cover “the physical and psychological integrity of a person” and went on to observe that
“Article 8 also protects a right to personal development, and the right to establish and develop relationships with other human beings and the outside world.”
Elusive though the concept is, I think one must understand “private life” in article 8 as extending to those features which are integral to a person’s identity or ability to function socially as a person. Professor Feldman, writing in 1997 before the most recent decisions, helpfully observed (“The Developing Scope of Article 8 of the European Convention on Human Rights”,  EHRLR 265, 270):
· “Moral integrity in this sense demands that we treat the person holistically as morally worthy of respect, organizing the state and society in ways which respect people’s moral worth by taking account of their need for security.”’
The Developing Scope of Article 8 of the European Convention on Human Rights”,  EHRLR 265, 270)
· In 2003 a journalist and a peaceful protester were stopped and searched by police officers using powers under section 44 of the Terrorism Act 2000. As originally drafted section 44 allows police to stop and search anyone within a designated area without any need for suspicion of any kind. An area can be designated whenever the person making it (generally a police chief) ‘considers it expedient’ for the prevention of acts of terrorism.
The European Court of Human Rights held that this broadly drafted power breached the right to a private life. The Court held that a forced search of a person and their belongings clearly interfered with the person’s private life. As such, any limitation had to be shown to be in accordance with law, pursue a legitimate aim and be necessary and proportionate. In this case section 44 was held to fail the first test.
The Court held that the powers of authorization and stop and search were not properly constrained and were not subject to adequate legal safeguards against abuse. The Court held that as “there is a clear risk of arbitrariness in the grant of such a broad discretion to the police officer” the power was not in accordance with law and therefore the limitation on the right to a private life could not be justified.
Bangladesh Human Rights Act
The Bangladesh Human Rights Commission was established by Bangladesh’s caretaker Government on 1 September 2008. was reconstituted in 2009 as a national advocacy institution for human rights promotion and protection. It is committed to the accomplishment of human rights in a broader sense, including dignity, worth and freedom of every human being, as enshrined in the Constitution of the People’s Republic of Bangladesh and different international human rights conventions and treaties to which Bangladesh is a signatory.
According to the former President of Bangladesh, Dr Iajuddin Ahmed, this Commission will “play a significant role in establishing a culture of respect for Human Rights with the co-operation of all concerned including the civil society, the public and private organizations.”
Justice (Retd) Golam Rabbani urged the government to form a national tribunal to protect citizens’ right to privacy. “The tribunal should operate in every district in Bangladesh and collect anecdotal evidence from ordinary people, so as to form an effective policy to protect their rights to privacy,” he said during a ‘National convention on right to privacy and data protection.’
He also urged that the Right to Information Act 2009 emphasizes that information that may endanger public security or impede the judicial process should not be disclosed
“The problem is that many people remain unaware of the RTI Act. Everyone should become familiar with the concepts of privacy and disclosure,” he said.
Sayed Marghub Morshed, former chairman of Bangladesh Telecommunication Regulatory Commission (BTRC) said that protecting individual’s personal information has become more crucial than ever before.
Privacy itself is guaranteed under Article 39(2)(a) and Article 43 of the fundamental rights of the Bangladesh Constitution. Article 33(2)(a) entrenches “the right of every citizen to freedom of speech and expression” and Article 43 guarantees “the privacy of home and correspondence and communications”. Privacy also guaranteed in Universal Declaration of Human Rights.
A perception study on privacy rights conducted recently by VOICE, shows that 83% respondents feel uneasy to share very personal information to others while 79% identified income as their 2nd most priority issue that they do not want to disclose and 75% people do not like to share information about their own resources.52% of respondents think that information would be unsafe and to used for another purposes.
· The need for privacy principles
The single greatest stumbling block to the effective regulation of information privacy in the UK is the lack of a coherent legal framework for the protection and promotion of individual privacy. As a result, this report strongly recommends that any proposed programmed of reform must be guided by a clear set of uniform principles, and an overarching commitment to fundamental human rights. New privacy protections must not only be compliant with the demands of the HRA, but also strengthen the right to respect for private and family life enshrined in Article 8 of the ECHR.
· Strengthening the right to privacy through legislative reform
It is important to reinforce the existing right to privacy. The government should consider reforming existing legislation that touches on matters of privacy in order to ensure that it is consistent with the privacy principles recommended earlier, and that it enhances – rather than undermines – the existing provisions of the HRA.
· Promoting greater regulatory coherence
Any system of regulation must be based on law. As discussed earlier in this assignment, there are significant gaps in the current legal regime, and in particular in the system of protection established by RIPA and DPA.
· Improved technological and organizational means of protection
The need for better integration between legal and non-legal means of protecting information privacy was emphasized earlier. Achieving this goal depends on developing ways of encouraging the design and use of privacy-protective technologies, assessing the impact of new information systems on privacy, encouraging stronger accountability practices in organizations, and involving NGOs in the protection and promotion of privacy.
Privacy plays an essential role in our society. It is vital to ensure that privacy is properly protected through the effective regulation of government surveillance. Moral integrity states that we treat the person holistically as morally worthy of respect, organizing the state and society in ways which respect people’s moral worth by taking account of their need for security. Since the coming to force of the Human Rights Act 1998, the law has developed and individuals have significantly greater scope to use the law to protect their privacy. Article 8 of ECHR has given everyone the right to protect their private life, family life and privacy. The article protects the private life of individuals against arbitrary interference by public authorities and private organizations. No one should interfere in another’s life but sometimes it is necessary to disclose some private information. So I want to conclude my paper with politician Mark Oaten statement “I concluded that however awful it may be, it’s better to have a press which can expose MPs’ private lives because it means we have a free press… it means we can expose corruption” .
1. This asylum instruction provides guidance on how to assess human rights claims under Article 8 of the European Convention on Human Rights (ECHR).
2. Handyside v. the United Kingdom, judgment of7 Dec. 1976, paras. 48-49.
3. R. Clayton and T. Tomlinson, 2009. The Law of Human Rights, Second Edition. Oxford: Oxford University Press. See also Connors v. the United Kingdom  40 EHRR 9. Para 82.
4. For engaged couples, see Wakefied v. the United Kingdom  66 DR 251; for cohabiting couples, Kroon v. Netherlands  19 EHRR 263; for same sex couples, Schalk and Kopf v. Austria  ECHR 30141/04. While the European Court has not specifically recognized transsexual unions under Article 8 it has referred to ‘the increased social acceptance’ in this area: see France v. B.  ECHR 40 and Sheffield & Homer v. the United Kingdom  27 EHRR 163. In Christine Goodwin v. the United Kingdom  35 EHRR 18 it found ‘no justification for banning the transsexual from enjoying the right to marry under any circumstances’.
5. For jurisprudence on the relationship between grandparent and grandchild, see Re J. ( Leave to Issue an Application for a Residence Order) CA 1 FLR 114; for foster parent and foster child, see Gaskin v. the United Kingdom  12 EHRR 36; ECHR 30141/04; for siblings see Senthuran v. Secretary of State for the Home Department  EWCA Civ 950  4 All ER 365.
6. L.K. (Serbia v. Secretary of State for the Home Department  EWCA Civ 1554. Para 8; J.Wadham, H. Mountfied, C. Gallagher, E. Prochaska, 2009. Blackstone’s Guide to the Human Rights Act 1998. Fifth Edition. Oxford: Oxford University Press. Page 218.
7. Huang v. Secretary of State for the Home Department  UKHL 11,  2 AC 167. Para 207See Boultif v. Switzerland  33 EHHR 50; Uner v. Netherlands  3FCR 340; Maslov v.Austria  ECHR (GC) 1638/03.
8. Launder v. the United Kingdom  25 EHRR; R.(on the application of Bermingham & Others v. Director of Serious Fraud  EWHC 200 (Admin).
9. Retrieved on March 24,2012From http://www.liberty-human-rights.org.uk/human-rights/privacy/index.php
10. Retrieved on March 24,2012 From http://www.liberty-human-rights.org.uk/human-rights/human-rights/the-human-rights-act/how-the-human-rights-act-works/index.php
11. M. Amos, 2006. Human Rights Law. Oxford: Hart Publishing. Pp. 343-344.
12. Raab and Goold, 2011; House of Lords Select Committee on the Constitution, 2009. Surveillance: Citizens and the State, 2nd Report of Session 2008-9, Vol.1: Report, HL-18 I, 9 February 2009. London: The Stationery Office. Para 126.
13. Retrieved on March 20,2012 from http://www.york.ac.uk/admin/hr/resources/policy/dpa_1998.htm
14. J. Wadham, H. Mountfied, C. Gallagher, E. Prochaska, 2009. Blackstone’s Guide to the Human Rights Act 1998. Fifth Edition. Oxford: Oxford University Press. Page 214.
15. R. v. Dyment  45 CCC (3d) 244. Paras 255-256.
16. Raab and Goold, 2011. Protecting information privacy. Manchester: Equality and Human Rights Commission. Pp. 28-29.
17. JUSTICE, 2011. Freedom from suspicion: Surveillance reform for a digital age. London: JUSTICE.
18. Joint Committee on Human Rights, 2008. Data Protection and Human Rights, Fourteenth Report of Session 2007-08, HC 132. London: The Stationery Office. Para 14.
19. Ibid. Footnote 16. The JCHR refers to the case of Edwards v. the United Kingdom  ECHR 203 46477/99, in which the failure to ensure the police passed information to the prison authorities about the risk posed by a mentally ill detainee contributed to the finding of the European Court of Human Rights that the UK had breached its positive obligation to protect life when that detainee killed his cellmate.
20. Ibid. See chapter 3 ‘Data protection in legislation’. Pp. 9-12.
21. See Home Office website, http://www.homeoffice.gov.uk/agencies-public-bodies/ips/about-us/suppliers/identity-cards/. Accessed 27/02/2012.
22. Raab and Goold, 2011. Protecting information privacy. Manchester: Equality and Human Rights Commission. Page 10.
23. “Youth cases” Retrieved on March 28, 2012 From http://baseswiki.org/en/National_Human_Rights_Commission,_Bangladesh
24. “Children Right Alliance” Retrieved on March 28, 2012 From http://baseswiki.org/en/National_Human_Rights_Commission,_Bangladesh
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26. Retrieved on March 28, 2012 From http://baseswiki.org/en/National_Human_Rights_Commission,_Bangladesh
27. Retrieved on March 28, 2012 From http://webcache.googleusercontent.com/search?q=cache:ZKx6Qhw__FwJ:www.voicebd.org/+Bd+human+rights+on+privacy&cd=3&hl=en&ct=clnk&client=firefox-a
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For jurisprudence on the relationship between grandparent and grandchild, see Re J. ( Leave to
Issue an Application for a Residence Order) CA 1 FLR 114; for foster parent and foster child,
see Gaskin v. the United Kingdom  12 EHRR 36; ECHR 30141/04; for siblings see Senthuran
v. Secretary of State for the Home Department  EWCA Civ 950  4 All ER 365.
L.K. (Serbia v. Secretary of State for the Home Department  EWCA Civ 1554. Para 8; J.
Wadham, H. Mountfied, C. Gallagher, E. Prochaska, 2009. Blackstone’s Guide to the Human
Rights Act 1998. Fifth Edition. Oxford: Oxford University Press. Page 218.
Raab and Goold, 2011; House of Lords Select Committee on the Constitution, 2009. Surveillance:
Citizens and the State, 2nd Report of Session 2008-9, Vol.1: Report, HL-18 I, 9 February 2009.
London: The Stationery Office. Para 126.
Joint Committee on Human Rights, 2008. Data Protection and Human Rights, Fourteenth Report
of Session 2007-08, HC 132. London: The Stationery Office. Para 14.
“Youth cases” Retrieved on March 28, 2012 From http://baseswiki.org/en/National_Human_Rights_Commission,_Bangladesh
“Children Right Alliance” Retrieved on March 28, 2012 From http://baseswiki.org/en/National_Human_Rights_Commission,_Bangladesh