عنوان مقاله [English]
With arriving to information and communications technology period, new issues and problems in relate to privacy and data protection laws have been introduced gradually that resolving those need to review in current laws or approve new and universal laws. The most countries such as Germany have the laws for data protection but some countries such as Iran have not universal and coherent laws in this field. Hence, the purpose of this paper is comparison of crimes against privacy in cyberspace between Iran and Germany. This comparison show that Iran law has serious flaws such as lack some of the principles governing personal data, incompletion the predicted principles, and referring some other principles to different regulations, that so it must be reviewed by the legislator. On the other, lack of comprehensive regulations regarding privacy protections hinders the understanding and proper implementation of data protection in the courts and administrative bodies. "Privacy Act" which was prepared for presentation to Parliament, has been resolved this problem partly, that if its problems is resolved and if approved, these deficiencies are partly removed.