Fake information : hard approach effect regarding freedom of expression and the soft approach on the internet in Europe. The case study of Lithuania, Germany and the United Kingdom

Abstract

Fake information have a negative effect on policies of human rights and it maintains a huge challenge to protect both. At the same time in order to bring change in the system EU started slowly moving from self-regulation to a co-regulation system and is still lacking ways in the midst of that change to release structures for human rights protection. This pushed us to gain a deeper look at the internet, specifically media platforms, and the scope of the hard and soft approaches to regulating disinformation/ misinformation effects on freedom of expression. The study conducts a case study analysis of three countries: Germany, Lithuania, and the UK. In a comparison of all three countries was discovered that the hard approach partly justifies the limitations of freedom of expression in the UK and Germany as proportionality fails in some aspects and the definitions are used too abstract whereas interestingly Lithuania has more specific term. This is probably the result of Lithuanian unique geographical and historical setting. In the soft approach, the results were pretty similar as Lithuania seemed to have more specific definitions and plans of action set. The conducted analysis revealed that legislation puts the foundation for the definition development on the specific issue.