LEGAL ACCOUNTABILITY IN THE DIGITAL SPHERE: A CROSS-JURISDICTIONAL STUDY OF SOCIAL MEDIA LAWS IN THE UK AND BAHRAIN

Purpose: The study seeks to explore the civil and criminal liabilities arising from social media usage in the United Kingdom and the Kingdom of Bahrain. By delving into the legal complexities within these jurisdictions, the research aims to propose a unified model law that bridges the regulatory gaps across borders. The objective is to harmonize social media regulations, ensuring a consistent and effective legal framework capable of addressing the growing challenges of online harms, while safeguarding individual rights. Theoretical Reference: The study draws on theories of civil and criminal liability, regulatory frameworks for digital interactions, and perspectives on freedom of speech and data protection. These theoretical foundations guide the analysis of the legal complexities surrounding social media usage in both jurisdictions. Method; A doctrinal and comparative methodology is utilized. The research analyzes legal texts, case law, and scholarly literature to assess the civil and criminal liability laws in the UK and Bahrain, exploring the disparities and similarities between these legal frameworks. Results and Conclusion: The findings highlight significant disparities between the two jurisdictions. The UK has a comprehensive legal framework, including GDPR and the Online Safety Bill, which contrasts sharply with Bahrain's reliance on stringent criminal statutes and limited civil remedies. The study concludes that a balanced approach to regulation is necessary, one that protects individual rights while effectively addressing social media misuse . Implications of Research: The study’s implications are broad, suggesting that the UK’s robust legal framework can offer valuable insights for Bahrain and other jurisdictions. The proposed unified model law could enhance consistency and effectiveness in regulating social media globally, contributing to legal scholarship and informing future legal reforms and policy interventions. Originality/Value: The originality of this research lies in its comparative approach to analyzing social media liability laws in two distinct jurisdictions. The proposal of a unified model law is a novel contribution that could significantly influence global legal standards for social media regulation, offering a path toward more consistent and balanced legal frameworks.


INTRODUCTION
In recent years, the global legislative landscape has undergone substantial shifts to address the multifaceted challenges posed by the rapid expansion of digital platforms and online interactions.This evolution is underscored by the introduction of comprehensive legislation such as the Online Safety Bill and the General Data Protection Regulation (GDPR), which highlight a growing recognition of the need for robust legal frameworks to ensure a secure and equitable online environment for users.The emergence of the COVID-19 pandemic has further accelerated this shift, emphasizing the increasing dependence on digital platforms for communication, commerce, and social engagement.As digital interactions become more prevalent, they unveil new vulnerabilities and challenges, including privacy breaches, online defamation, the dissemination of false information, and cyberbullying.
The proliferation of social media platforms has introduced a range of complex legal issues related to civil and criminal liability.These issues require a nuanced understanding of how different jurisdictions address the misuse of social media and the associated legal repercussions.In the United Kingdom, the regulatory approach to social media is characterized by comprehensive legislation, including the GDPR and the Online Safety Bill.These regulations aim to provide a robust framework for protecting users and addressing various forms of digital harm.The GDPR, for instance, sets out stringent requirements for data protection and privacy, while the Online Safety Bill seeks to enhance the regulation of online platforms to mitigate risks associated with harmful content and behaviors.
In contrast, Bahrain's approach to social media regulation primarily relies on criminal statutes, with limited provisions for civil remedies.The Bahraini legal framework imposes strict measures against social media misuse but does not emphasize personal data protection under Law No. 30 of 2018.This divergence in regulatory approaches highlights significant differences in how social media liability is addressed across jurisdictions.The reliance on criminal statutes in Bahrain contrasts with the more comprehensive legislative measures in the UK, reflecting varying priorities and strategies in managing digital harms.
Understanding the distinction between civil and criminal liability is crucial, as a single act or omission can give rise to both types of liability.Civil liability typically involves claims for damages or remedies resulting from harm caused by the defendant's actions, while criminal liability involves prosecution by the state for violations of criminal laws.The legal frameworks in civil law and common law jurisdictions often adopt divergent approaches in defining and enforcing these liabilities, adding complexity to the legal landscape.This complexity is further compounded by the global nature of digital interactions, which can transcend national borders and complicate efforts to achieve consistent regulatory outcomes.
Jurisdictions worldwide have adopted varied perspectives on the prosecution of social media misuse as a criminal offense.Some legal systems view such misconduct as a private matter, resolved through redress between private individuals or entities, while others treat it as a matter of public concern requiring state intervention.This disparity in legal treatment can stem from differences in civil and criminal liability theories and their application within existing and proposed legal frameworks.As digital platforms continue to evolve, the need for harmonized regulatory approaches becomes increasingly evident.
The increasing reliance on digital platforms for communication, commerce, and social interaction underscores the importance of developing effective legal mechanisms to address the challenges of online misconduct.The disparities between the regulatory approaches of the UK and Bahrain illustrate the need for a unified model law to harmonize social media regulations globally.Such a model would aim to enhance consistency and effectiveness in addressing digital harms, providing better protection for individuals in an increasingly interconnected world.By exploring the complexities of civil and criminal liability theories and their application to social media usage, this study seeks to contribute to the broader discourse on social media regulation and online user protection.Through a comprehensive analysis of legal texts, case law, and scholarly literature, the research aims to offer valuable insights and recommendations for policymakers, legal practitioners, and scholars.The goal is to provide a nuanced understanding of how different jurisdictions handle social media liability and to propose practical solutions for achieving global consistency in social media regulation Hall (1943).

LEGAL PERSPECTIVES ON SOCIAL MEDIA: BAHRAIN VS UK
By utilizing both theoretical frameworks and practical methodologies, it will be the aim to conduct a comprehensive analysis and comparison of legal perspectives within the realm of available concurrent materials related to the research area.
The research approach can be classified into the following heads of study: 1) Black Letter Doctrinal Analysis: This involves a comprehensive study of various legal provisions in Bahrain through regular courts.The objective is to observe if the law is coherent and rational based on the general principles of Sharia Law as well as the requirements of the growing society.
2) Case Studies Analyzes: A selection of case studies will be analyzed to supplement the research and enhance understanding of the position of the law.These case studies will critically examine legal responses to social media misuse in Bahrain and the UK, drawing insights from global standards and practices.
3) Case Selection Criteria: Cases will be selected based on their relevance to social media laws, including but not limited to instances of defamation, cyberbullying, and dissemination of fake news.Priority will be given to cases that illustrate key legal principles and have significant implications for social media regulation.
4) Analysis Framework: Each case will be analyzed using a structured framework that considers the legal context, key issues, judicial reasoning, and implications for social media regulation.The analysis will focus on identifying trends, strengths, and weaknesses in legal responses to social media misuse, both in Bahrain and the UK.

ANALYZING LEGAL LANDSCAPES
The study has extensively examined the legal framework of the Kingdom of Bahrain, with a specific focus on laws of civil liabilities, Information Technology (IT) and cybercrime regulations, criminal statutes, data protection laws, and associated regulations.The current legal landscape in Bahrain imposes severe criminal penalties for a range of actions, particularly those involving social media platforms, as part of efforts to safeguard national integrity.
Consequently, a key objective of this research has been to decipher the underlying rationale behind lawmakers' decisions to establish such stringent penalties.Through meticulous analysis, this study has sought to draw parallels between the rights articulated in international conventions and principles and the ethical standards entrenched in Sharia Law.This comparative approach sheds light on the intricate interplay between legal frameworks and ethical considerations, providing valuable insights into the broader implications of Bahrain's legal stance on issues such as freedom of speech, defamation, and cyber-related crimes." In

UNDERSTANDING LEGAL DYNAMICS
In the contemporary digital landscape, the responsible use of social media entails adherence to a multitude of local and international laws and regulations governing a wide array of issues, including defamation, invasion of privacy, and intellectual property rights.Users are expected not only to comply with legal requirements but also to respect the terms of service of social media platforms, safeguard their personal information, refrain from engaging in harmful behaviors such as cyberbullying and sharing harmful content, and exercise critical judgment in evaluating and sharing content.
When exploring civil liability and criminal justice theories within the legal frameworks of the United Kingdom and the Kingdom of Bahrain concerning social media, it is imperative to grasp the intricate nuances of these legal concepts and their practical applications.Civil liability, fundamentally, pertains to the legal obligation of individuals or entities to compensate others for damages or losses resulting from their actions or negligence.In the realm of social

SOCIAL MEDIA CIVIL LIABILITY & CRIMINAL THEORIE
In delineating the contours of civil liability and criminal theories applicable to social media misuse, it is imperative to examine various approaches that underpin the legal frameworks designed to address such misconduct.The article will embark on a comprehensive Lastly, rehabilitation emphasizes the rehabilitative aspect of punishment, aiming to reform offenders and reintegrate them back into society.This approach views punishment as an opportunity for personal transformation and societal reintegration, emphasizing the potential for rehabilitation and redemption.
In synthesizing these diverse perspectives, endeavors to provide a comprehensive understanding of the multifaceted dynamics of civil and criminal liability theories in the context of social media misuse.By elucidating these theoretical frameworks, the study aims to shed light on the complexities of legal responses to social media-related offenses and contribute to the ongoing discourse on effective regulatory strategies in the digital age Brooks, T. (2012).

SOCIAL MEDIA REGULATION IN THE UNITED KINGDOM
In line with the commitment to bolster online safety, the proposed Online Safety Bill aims to provide additional protections against social media misuse, targeting abuse, harassment,

REGULATION OF SOCIAL MEDIA IN THE KINGDOM OF BAHRAIN
In Bahrain, there is no specific law dedicated to the protection of social media platforms.
However, some several laws and regulations govern internet usage and online activities, including those related to social media.Among these laws are: 11 not, in itself, criminalize online freedom of thought, opinion, and expression, but it allows for the prosecution of free expression, as it complements the Media Regulation Law of 2002.This is evident in Article 1 of the law, which recognizes the right to thought and expression, bound by two conditions: respect for Islamic pillars and a prohibition on inciting sectarianism.
Freedom of the press is subjected to these restrictions as well.
For instance, Article 70 of the Media Regulation Law penalizes content deemed to ridicule national security, categorized as "fake news," or critical of public figures and states with which Bahrain maintains strong diplomatic ties.This legal framework primarily focuses on criminal sanctions to protect the interests of the state and its authorities, while the laws have not yet developed to sufficiently address issues that affect individual rights and freedoms.
Although the general sanctions of criminal law could ideally apply in situations where a wrongdoer is punished, there remains a lack of clear provisions for civil damages or compensation for victims.
This context is further illustrated by the case of Bahrain Telecommunications Regulatory Authority v.The Internet Society (2018) (Bahrain).In this case, the Bahrain Telecommunications Regulatory Authority (TRA) took action against the Internet Society for allegedly violating local laws related to internet governance and data protection, particularly concerning the handling of personal information.The outcome of this case raised significant discussions surrounding data protection, privacy rights, and the regulation of internet governance in Bahrain, reflecting broader issues of compliance with international standards.
This case exemplifies the ongoing tension between regulatory frameworks intended to protect state interests and the need for robust protections of individual rights in the digital landscape.
The law of defamation in Bahrain has seen significant changes since 2011-13, since then the Government has imposed a sanction over misusing the freedom of speech and expression The law is quite restrictive concerning fake news and media regulation, where there are arrests and imprisonment for publishing fake news that has the potential to harm public order on social media.The area of focus for the same in Bahrain is to have strict regulation over the media to ensure that there is no negative impact on the lives of the people and the stability of the public order.Authorities issue official statements warning against the "misuse" of social media.

Cybercrime
There have been numerous reports and incidents where investigations have led to the penalization of various persons and institutions in and out of Bahrain that have resulted in such acts that had negative impacts on the people and were seen as an attack on their lives, people.Under the new draft press and media law that is currently under final revision before submission to parliament, online news reporters can be subject to fines for publishing content that is deemed to fall into a list of vaguely worded categories including "false news, insulting the monarchy, subjecting it to criticism, or imposing responsibility on it for the actions of the government, undermining the regime, news that will affect the value of the national currency," statement" that may be damaging to national security or public order may be imprisoned for up to two years.Under Article 309 of the Penal Code, any "expression against one of the recognized religious sects" or ridicule of their rituals may be punished by a fine of 100 dinars ($260) or a prison term of up to one year.In May 2019, the king ratified an amendment to article 11 of the terrorism law that criminalizes propagating, glorifying, justifying, favoring, or encouraging acts that constitute terrorist activities, with a penalty for up to five years in prison and a fine of between 2,000 and 5,000 dinars ($5,200 to $13,200).Following the approval of this amendment, activists and lawyers have warned social media users that acts of commenting, retweeting, liking, or forwarding could meet the criteria of the abovementioned crime.
Individuals are frequently detained and prosecuted for online activities that offend the Kingdom.Concerning issues concerning privacy, Bahrain enacted Law No. 30 of 2018 concerning Personal Data Protection ("PDPL") on July 12, 2018(Bahrain).The PDPL is the main data protection regulation in Bahrain.
The Personal Data Protection Authority can issue orders to stop violations, including issuing emergency orders and fines while the law carries criminal penalties for businesses violating certain PDPL provisions.Civil compensation is also allowed for any individual who has incurred damage arising from the processing of their data by the data manager, or PDPL violations by a business's data protection supervisor.There is no specific online privacy regulation in Bahrain.
In 2018, the Interior Ministry pointed out that the cybercrime legislation covered crimes specifically related to information technology, while insulting language was covered by the 1976 Penal Code.The Shura Council had proposed a punishment of between a day and three years in jail and fines ranging between BD1,000 (€2,500.) and BD 50,000.(€125,000.).
However, Parliament at the time said the penalties were not in line with other punishments.

According to the Bahrain Interior Ministry Report on Cybercrime Legislation and
Insulting Language (2018) and the Shura Council's proposal on punishments for insulting language during parliamentary debates, there has been significant discussion regarding the alignment of penalties.Compliance by Organizations: Analyzing how businesses and organizations operating in Bahrain comply with the PDPL, including their practices for obtaining consent, handling data, and ensuring data security.This also includes assessing how these entities manage and respond to data breaches.
Effectiveness in Addressing Modern Challenges: Challenges Related to Social Media: The study assesses the law's effectiveness in addressing challenges specific to social media platforms.This includes evaluating how well the PDPL addresses issues such as: Data Collection and Processing: How the law regulates the collection and processing of personal data on social media, including the handling of user-generated content and the use of data for targeted advertising.
User Consent and Privacy: The extent to which the PDPL ensures that users give informed consent for their data to be used on social media platforms and how well it protects user privacy.
Data Security: Measures taken to secure personal data from unauthorized access or breaches, especially in the context of social media platforms which are often targeted by cyberattacks.
Cross-Border Data Transfers: How the PDPL regulates the transfer of personal data outside Bahrain, particularly in relation to international social media platforms operating within and outside the country.
2) Recommendations for Enhancement: Strengthening Consent Mechanisms: The study recommends enhancing provisions related to obtaining explicit and informed consent from users for the collection and processing of their data on social media platforms.This may involve clearer consent forms and more transparent data usage policies.
Improving Data Security Measures: Suggesting stronger data security requirements for organizations to protect personal data, including advanced security technologies and regular audits.
Enhancing Enforcement: Recommending the development of more robust enforcement mechanisms to ensure compliance with the PDPL, such as stricter penalties for violations and more effective oversight by regulatory authorities.
Updating Legal Provisions: Proposing updates to the PDPL to address emerging issues related to social media, such as the regulation of new data processing technologies and practices.
1) Contribution to Legal Frameworks and Individual Rights: Understanding Legal Frameworks: By providing a thorough analysis of the PDPL, the study contributes to a better understanding of Bahrain's legal framework for data protection and its alignment with international standards.
Protecting Individual Rights: The study emphasizes the importance of enhancing data protection measures to better safeguard individual rights in the online environment, ensuring that personal data is handled responsibly and that privacy is upheld in the face of evolving digital challenges.
selecting the United Kingdom for comparative analysis, several factors come into play: Recent governmental initiatives in the UK have introduced a new category of civil orders aimed at preventing harm or criminal activities.These encompass a wide range of areas such as anti-social behavior, sexual offenses, restraining orders, and football banning orders.The UK's existing legislative framework provides robust mechanisms for addressing social media abuses, evidenced by numerous court cases and legal precedents.This paper will meticulously examine UK case law and the ensuing legal ramifications arising from the misuse or abuse of social media platforms.By exploring the feasibility of incorporating civil liability aspects akin to those in the UK, this research aims to enhance the understanding of legal responses to similar issues.For instance, the Protection from Harassment Act 1997 offers civil remedies like injunctions and damages to safeguard individuals from harassment, while defamation remains actionable in civil courts without limits on damages.Additionally, this study will scrutinize differences in liability between individuals and social media service providers, evaluate the proportionality of laws concerning international standards, and assess alignment with Sharia Law principles regarding punishment severity.Moreover, Bahrain's potential to set precedents for other Islamic or Sharia law nations in liberalizing criminal sanctions related to international Legal Accountability in the Digital Sphere: a Cross-Jurisdictional Study of Social Media Laws in the UK and Bahrain ___________________________________________________________________________ Rev. Gest.Soc.Ambient.| Miami | v.18.n.8 | p.1-20 | e07819 | 2024.7 cyber-related offenses will be explored.Further considerations include examining the compatibility of Bahrain's legal principles with evolving digital societal paradigms, exploring the balance between criminal liability and civil remedies, and contemplating potential amendments to Bahrain's Civil Act to address internet misuse-related issues Al Markh (2024).
discussion encompassing three distinct perspectives on civil liability, namely, Corrective Justice Theory, Civil Recourse Theory, and Moral Enforcement Rights Theory.The Corrective Justice Theory hinges on the premise of rectifying the harm suffered by the plaintiff Sebok, A. (2007), emphasizing the responsibility of the wrongdoer to correct the inflicted wrong.This perspective underscores the importance of restoring balance and fairness by holding individuals accountable for their actions and facilitating redress for aggrieved parties.Conversely, the Civil Recourse Theory aligns with the notion of holding individuals accountable for the wrongs they commit Gold, A. (2010).Further emphasizing the correlation between wrongdoing and accountability.It emphasizes the role of civil recourse as a mechanism for seeking accountability and ensuring that perpetrators are held responsible for their actions.The Moral Enforcement Rights Theory advocates for the enactment of laws aligned with a private right of action for the enforcement of breached rights.This approach aims to coerce individuals into redressing the wrongs they have committed by providing legal avenues for affected parties to seek restitution and enforce their rights Gutteridge, H. C. (1971).In addition to civil liability theories, several perspectives on criminal liability warrant consideration.The deterrence and incapacitation Clarke, R., & Felson, M. (Eds.).(2004), theories of punishment revolve around conducting a cost-benefit analysis to dissuade defendants from engaging in criminal activities (specific deterrence) and to reduce overall criminal behavior in society (general deterrence).This encompasses mechanisms such as instilling fear of punishment and incapacitating offenders to prevent future offenses.Moreover, retribution underscores the principle of imposing punishment when deemed justifiable, emphasizing the notion of retributive justice in meting out appropriate penalties for criminal wrongdoing.It embodies the concept of balancing the scales of justice by ensuring that offenders face consequences commensurate with the severity of their actions.
and content promoting harmful behavior by various categories of individuals and legal entities.This legislative initiative reflects the UK government's proactive stance in addressing emerging challenges in the digital sphere and underscores its commitment to ensuring a safe online environment for all users.Additionally, the Communications Act 2003 imposes obligations concerning children's programming, news provisions, and accessibility to internet services, with specific provisions addressing communications via social media platforms Section 127 of the Communications Act 2003 (UK).In particular, addresses the criminality associated with the misuse of social media platforms, criminalizing improper use of public electronic communications networks.The UK's legislative landscape demonstrates a proactive approach to combatting social media misuse, with several high-profile cases serving as illustrative examples of legal enforcement against offenders.The wealth of court cases and reported incidents underscores the efficacy of existing legal mechanisms and the judiciary's resolve in addressing social mediarelated offenses.Through a combination of legislative measures, judicial enforcement, and public awareness initiatives, the UK continues to navigate the evolving challenges of social media governance, striving to uphold fundamental rights and promote online safety for all Campbell v Mirror Group Newspapers Ltd ([2004] UKHL 22).
Law No. 60 of 2014(Bahrain), With the rapid onset of the digital era and the wider access of people to social media.With the multiple instances of the past years, it can be observed how the magnitude of the punishments and fines imposed on such actions has helped the government to significantly reduce the instances of actions of libel, slander, defamation, and other actions that are a threat to the Kingdom.

Legal
Accountability in the Digital Sphere: a Cross-Jurisdictional Study of Social Media Laws in the UK and Bahrain ___________________________________________________________________________ Rev. Gest.Soc.Ambient.| Miami | v.18.n.8 | p.1-20 | e07819 | 2024.12 The actions taken utilizing the Telecommunication Law 2002, the measures taken between 2011-13 by authorities such as the Bahrain Independent Commission of Inquiry and the Information Affairs Authority and the 2014 Law about Information Technology Offences (Law No. 60 of 2014 (Bahrain), have been successful in the endeavor to maintain and preserve the national integrity of the Kingdom, and the same can be also observed in the 2020 Amendments (as a Bill) to the above mentioned 2014 Law to criminalize online defamation and slander against persons on social media Ross, D. L. (2018).The Ministry of Information Affairs (MIA) blocks websites that violate Articles 19 and 20 of the Press Rules and Regulations, which prohibit material judged as "instigating hatred of the political regime, encroaching on the state's official religion, breaching ethics, encroaching on religions and jeopardizing public peace or raising issues whose publication is prohibited by the provisions of this law.Ministry of Information Affairs (MIA).(n.d.).Press rules and regulations.Kingdom of Bahrain.http://www.mia.gov.bh"The publication of false news is deemed a crime according to article 70 of the same law.
Multiple laws, including the Penal Code and terrorism laws, criminalize free speech and online activities.Criminal penalties for online speech are currently enforced under Decree No. (47) of 2002: Press and Publications Law, (Bahrain) which does not specifically mention online activities, but has been applied to digital media.The law allows for prison sentences from six months to five years for publishing material that criticizes Islam, its followers, or the King, as well as content that instigates violent crimes or the overthrow of the government.Article 70 of the Decree No. (47) of 2002 penalizes certain types of content, including "false news," that undermines public security and criticism of presidents or states with which Bahrain has diplomatic ties.In addition, the Telecommunications Law 2002 contains penalties for several online activities, such as the transmission of messages that are offensive to public policy or morals Clarke, R., & Felson, M. (Eds.).(2004).

Legal
Accountability in the Digital Sphere: a Cross-Jurisdictional Study of Social Media Laws in the UK and Bahrain ___________________________________________________________________________ Rev. Gest.Soc.Ambient.| Miami | v.18.n.8 | p.1-20 | e07819 | 2024.13 Law No. 60 of 2014 concerning Information Technology Crimes criminalizes the illegal access of information systems and of pornographic electronic materials.Additionally, sentences can be longer than what is mandated by the Decree No. (47) of 2002 if users are tried under the penal code or terrorism laws-especially in relation to social media, where the Press and Publication Law is not used.Under Penal Code of Bahrain (Decree Law No. 47 of 2002 (Bahrain), any user who "deliberately disseminates a false It can be seen as to how the law regulating and penalizing online defamation using social media platforms is a strict criminal penalty imposed.This research shall thus attempt to divulge into the details and intricacies of understanding the rationale of the legislators by mapping the origins of the law, comparing it with civil liability of damages and to an extent comparing the positions with that of the United Kingdom which has a completely different model of law to tackle such legal issues Mohd-Sulaiman, A. N., & Hingun, M. (n.d.).8NAVIGATING SOCIAL MEDIA LAWSThe significant advancement beyond existing research on criminal and civil liability theories lies in situating them within the realm of social media.Unlike current literature, this study adopts a comparative approach to analyzing civil and criminal wrongs as defined by law, evaluating their effectiveness in addressing the growing use of social media platforms for various purposes.Notably, the study provides clarity on the intricacies of civil and criminal laws related to social media in the Kingdom of Bahrain, a jurisdiction with limited available resources or writings on its legal framework.Further emphasized by its effort to bridge the gap in understanding social media laws in both civil (Bahrain) and common law (United Kingdom) jurisdictions, from theoretical and practical perspectives.For instance, the case of Monroe v.Hopkins (2017) serves as a pertinent example within the UK context.This libel case, involving defamatory tweets by columnist Katie Hopkins against writer Jack Monroe, highlights the potential civil liabilities associated with defamation on social media platforms.The court's ruling in favor of Monroe, awarding damages and legal costs, underscores the importance of robust legal frameworks in addressing reputational harm in the digital age.By consolidating knowledge of these legal landscapes, the study not only facilitates further research in the legal domain but also enriches access to high-quality materials for legal studies and contributes to Bahraini legal jurisprudence.Additionally, the proposal for a unified model law represents a significant step towards advancing legal developments in this research area.By suggesting a standardized legal framework applicable across different jurisdictions, it aims to streamline legal responses to social media-related issues and foster international cooperation in combating online misconduct.Furthermore, the study delves into additional legal dimensions consistent with Bahrain's Personal Data Protection Law (Law No. 30 of 2018).It focuses on the obligations outlined in the law regarding personal data protection and usage restrictions, including stringent requirements for obtaining individual consent for data processing and the security measures Bahrain ___________________________________________________________________________ Rev. Gest.Soc.Ambient.| Miami | v.18.n.8 | p.1-20 | e07819 | 2024.15 that must be implemented to protect data.By analyzing how the Personal Data Protection Law is implemented in Bahrain and assessing its effectiveness in addressing modern challenges related to social media, the study contributes to a better understanding of legal frameworks and offers recommendations to enhance data protection and individual rights in the online environment Goldof the Personal Data Protection Law (PDPL): Purpose and Scope: Law No. 30 of 2018, also known as the Personal Data Protection Law (PDPL), is Bahrain's primary legislation governing the collection, processing, and protection of personal data.It aims to safeguard individuals' privacy and ensure that personal data is handled in a lawful, fair, and transparent manner.Key Provisions: The law includes key provisions such as requirements for obtaining consent, data processing principles, rights of data subjects, and obligations of data controllers and processors.It also addresses data security measures and mechanisms for reporting and handling data breaches.2) Implementation of the PDPL: Regulatory Framework: The study evaluates how effectively the Bahraini government and relevant regulatory bodies have implemented and enforced the PDPL.This involves examining the establishment of oversight authorities, the issuance of guidelines, and the development of enforcement mechanisms.
the comparative analysis of civil and criminal liability laws surrounding social media use in the United Kingdom and the Kingdom of Bahrain highlights both similarities and disparities in their approaches.While the UK has developed comprehensive legislation and enforcement mechanisms to address online harms, Bahrain predominantly relies on criminal statutes with limited civil remedies.Despite efforts to combat issues such as cyberbullying and fake news, both jurisdictions face challenges in effectively regulating social media platforms to ensure the protection of individuals' rights and the maintenance of societal order.Moving forward, there is a pressing need for harmonization of social media laws across jurisdictions to promote consistency and effectiveness in addressing online harms.This requires a balanced approach that safeguards freedom of expression while holding individuals accountable for harmful behavior online.Policy interventions should focus on legislative reforms, enhanced enforcement measures, and public awareness campaigns to create a safer and more responsible online environment for all users.11 RECOMMENDATIONS 1) Cyberbullying and Defamation Legislation: Introduce or enhance laws specifically targeting cyberbullying and online defamation in Bahrain.This could involve updating existing laws such as the Penal Code (Law No. 15 of 1976) to include clear definitions and penalties for cyberbullying and online defamation.2) Data Protection Laws: Strengthen Bahrain's data protection framework by amending the existing Personal Data Protection Law (Law No. 30 of 2018).These amendments should aim to better protect individuals' data on social media platforms, ensuring stringent measures against unauthorized data access and breaches, specifically by amending the following articles: -Article 4: To ensure that personal data is collected and processed in a lawful, fair, and transparent manner."Personal data shall be collected and processed in a lawful and fair manner, with specific provisions for data collected through social media platforms.The data subject must be informed of the purposes for which their data is being processed, including third-party sharing."-Article 8: To enhance the requirements for obtaining the data subject's consent before processing their data."Consent must be obtained from the data subject before processing Legal Accountability in the Digital Sphere: a Cross-Jurisdictional Study of Social Media Laws in the UK and Bahrain ___________________________________________________________________________ Rev. Gest.Soc.Ambient.| Miami | v.18.n.8 | p.1-20 | e07819 | 2024.18 their personal data.The consent should be explicit, informed, and provided through a clear and concise statement, particularly in cases involving social media platforms.The data subject shall have the right to withdraw consent at any time."-Article 16: To tighten the security measures imposed on data controllers."Data controllers must implement appropriate technical and organizational measures to ensure the security of personal data.These measures must include protections against unauthorized access, cyber threats, and data breaches, with specific guidelines for data processed through social media platforms."-Article 19: To expand the scope of individuals' rights to access, rectify, and delete their personal data."Data subjects have the right to access their personal data, request correction, and demand deletion of their data.These rights should be enforceable with respect to all data processing activities, including those conducted on social media platforms.Data controllers must respond to such requests promptly and provide clear procedures for data subjects to exercise these rights."3) Platform Regulation: Implement regulations in Bahrain to govern the content moderation practices of social media platforms.These regulations should hold platforms accountable for addressing harmful content and protecting user safety, possibly through a dedicated regulatory body overseeing compliance.4) Digital Literacy Initiatives: Invest in educational programs in Bahrain to promote digital literacy and online safety awareness among the population, especially the youth.These initiatives should complement legal measures, helping individuals understand the risks of online interactions and how to protect themselves.REFERENCES (Bahrain Telecommunications Regulatory Authority v.The Internet Society, 2018).(Bahrain Interior Ministry Report on Cybercrime Legislation and Insulting Language," 2018; Shura Council Proposal on Punishments for Insulting Language, Parliamentary Debates on Penalty Alignments) .Amendments to Law No. 60 of 2014 on Combating Cybercrime in the Kingdom of Bahrain.