Online reputation protection

The laws that help remove fake reviews, by country

GDPR, DSA, CCPA, PIPEDA, LGPD and more: the legal frameworks behind fake review removal and online reputation defense, explained simply.

On this pageEuropean Union — GDPR & DSAUnited KingdomUnited StatesCanadaLatin AmericaAsia-PacificHow these levers are applied

Fake reviews are a global problem — and every region has its own legal levers to fight them. This page maps the main frameworks used to remove fake or defamatory reviews and to protect personal data, region by region. Wherever your business operates, there is almost always a law that supports your case.

A. European Union — GDPR and DSA

  • GDPR (EU) 2016/679: if a review contains false or excessive personal data, you can demand rectification or erasure (arts. 16-17). The platform must answer within one month; if it does not, you can complain to your national data protection authority.
  • Digital Services Act (EU) 2022/2065: art. 16 notice-and-action — report illegal content and the platform must process the notice and justify its decision (art. 17). It is the lever that unlocks most cases in the EU.
  • National civil and criminal laws: every member state protects honor and reputation (civil defamation); some also penalize slander. Names vary by country.

B. United Kingdom

  • UK GDPR + Data Protection Act 2018: the same rectification and erasure rights as in the EU.
  • Defamation Act 2013: civil action for serious harm to reputation caused by false statements of fact.
  • Platform policies: Google, Trustpilot and TripAdvisor remove reviews that breach their guidelines, regardless of jurisdiction.

C. United States

  • Section 230 (Communications Decency Act): platforms are generally not liable for third-party content — so the working lever is each platform's own policies (Google, Yelp, Trustpilot, Facebook), which prohibit fake and fraudulent reviews.
  • CCPA/CPRA (California): consumers can request deletion of their personal data; useful when a review exposes private information.
  • FTC rule on fake reviews (2024): prohibits creating, selling or buying fabricated reviews — solid ground to report coordinated attacks.
  • State defamation laws: civil actions for false statements of fact, with variations by state.

D. Canada

  • PIPEDA: right to correct or withdraw personal information held by organizations, including review platforms.
  • Provincial defamation law: e.g. the Ontario Libel and Slander Act or the Quebec Civil Code (art. 1457, civil liability).
  • Competition Bureau: enforcement against false or misleading reviews.

E. Latin America

  • Brazil: LGPD (data subject rights), Marco Civil da Internet (platform notice obligations) and Civil Code protection of honor.
  • Mexico: LFPDPPP — ARCO rights (access, rectification, cancellation, opposition).
  • Argentina: Personal Data Protection Law 25.326 (habeas data).
  • Chile and Colombia: Law 19.628 and Law 1581 of 2012 (data protection), plus civil defamation actions.

F. Asia-Pacific

  • Australia: Privacy Act 1988 and ACCC enforcement against fake or misleading reviews.
  • Singapore: PDPA (correction of personal data) and the Protection from Harassment Court for defamatory content.
  • Japan: APPI (correction and deletion requests); platforms must act on clearly illegal posts.
  • South Korea: PIPA and strict platform duties to delete defamatory content.
  • India: DPDP Act 2023 (correction and erasure of personal data) and IT intermediary rules.

G. How these levers are applied

  1. Platform policies first: in every market, the fastest path is the platform's own removal reasons (spam, conflict of interest, non-customer, illegal content).
  2. Data protection claims: GDPR-like laws exist on every continent — demand rectification or erasure when the review exposes personal data.
  3. DSA notices (EU): a formal notice that forces processing and justification.
  4. Civil or criminal defamation: where local law protects honor and reputation, as a last resort for serious cases.

See how we combine them in our method.

Want us to apply them to your case? Tell us where your business operates and what is happening; we will send you a free diagnosis of what is removable and under which law.

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Information, not legal adviceThis page is a general summary; laws change and their application depends on each case. For complex situations, consult a local legal professional.

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