“ For example, in the Federal Republic of Germany, the Federal Constitutional Court, in its famous "census decision", recognized that the State's storage of personal data, especially in computer systems, could influence citizen's behaviour and endanger their general liberty of action and must therefore be considered as a violation of civil liberties ("right of informational self-determination") , which requires an express and precise legal basis. ”

“ With respect to personal data, however, there are additional legal problems that mainly concern gathering, storing and linking personal data in the course of criminal proceedings. In this field of "privacy protection in criminal matters", legal requirements vary considerably among countries. Differences between various legal systems are found not only in substantive law requirements but also in the constitutional background, legal context and legislative technique of the relevant provisions. ”