Article 8 of the ECHR provides for the protection of the right to privacy. This right ensures ‘the development and fulfilment of individuals’ personality’.46 On this basis, the ECtHR has developed extensive case law concerning personal data protection. In addition, a series of legal standards have been developed by the Council of Europe for the protection of privacy and personal data, notably in the context of social media. In particular, the Council of Europe Modernised Convention on the protection of individuals with regard to automatic processing of personal data (Convention 108+), which is open to any country in the world and which sets international standards, should serve as the universal treaty for data protection.