Comparative analysis of confidentiality of personal health data in the law of the United States of America and European Union law

With the impact of digitalisation, the protection of personal data has become a priority issue that must be re-evaluated within the context of fundamental rights and freedoms in contemporary legal systems. In particular, health data represents one of the most legally protected categories of personal data, as it contains highly sensitive information about an individual's private life and is directly linked to human dignity. This study examines the theoretical foundations, national and international regulations, and judicial decisions related to the protection of personal health data, employing a comparative legal method across the United States, the European Union, and Turkey. The analysis identifies key national and international differences and offers recommendations to enhance legal harmonisation and compliance.