The right to be forgotten as an aspect of the personality right

The right to be forgotten as an aspect of the personality right has been examined in this study. In this context, the analysis has been carried out within the scope of both Continental European and Anglo-American legal systems. The aim of this approach is to reveal the application of the right to be forgotten in different legal systems, so that it can be determined the aspects of the said right and its position before the personality right. As required by the said aim, firstly the historical development and legal bases of the right to be forgotten have been examined, and afterwards the elements, scope, limits and implementation of the right have been determined. Finally, the criteria for establishing the balance between the right to be forgotten and freedom of expression and potential remedies in case of the violation of the said right have been explained.