Abstract
A comparative legal analysis has been conducted on the legislation and practices regarding the protection of patients' personal data in the healthcare systems of Russia, the USA, the EU, China, and several other Asian countries. The main research methods employed include comparative-legal analysis, formal-legal analysis, expert-analytical methods, visualization techniques, and structural analysis. The aim of the study is to analyze the legislation related to the protection of patients’ personal data in healthcare across different countries and to identify recommendations for Russia. The findings indicate that the USA and the EU are leaders in this area, with specific laws governing the protection of personal data in healthcare that impose strict requirements on medical data operators and significant penalties for violation. It is noted that Russian legislation on data protection in healthcare aligns with global trends toward digitalization and personal data protection. However, challenges remain in law enforcement due to underfunding of IT infrastructure in medical organizations, a shortage of qualified personnel, and low digital literacy among medical staff. The results of this study provide a foundation for further scientific research into the transformation of medical privacy protection systems in light of advancements in big data technologies, AI, and the Internet of Things. The paper advocates for a differentiated legal regulation based on categories of information (such as genetic and biometric data), argues for strengthened liability for violations, and proposes specific legislative innovations.
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