The Dispute Settlement Design of International Organizations’ Data Protection Regimes: Comparing the UN and the EU Frameworks

International organizations (IOs) both collect and process large amounts of personal data. This article analyses the United Nations (UN) and the European Union (EU) internal data protection regimes, with a particular emphasis on their dispute settlement design. While IOs have a binding obligation to provide ‘reasonable alternative means’ of redress when they cause harm to others, there has been a growing trend to create special regimes for third party claims arising out of their operations, including in the field of data protection. The first section argues that data protection has become an integral part of the debate on the accountability of IOs and that regional private law models have strongly influenced IOs’ internal regimes. The second section highlights the variability in level of protection and dispute settlement design under the EU and the UN respective frameworks. Ultimately, it concludes that the UN is increasingly moving towards a rights-based approach granting private individuals actionable rights.