HURBAIN v. BELGIUM JUDGMENT rather its continued availability online. The contemporary debate on this aspect of the “right to be forgotten” was undoubtedly reinforced by the CJEU’s Google Spain judgment (C-131/12) concerning a request for the operator of a search engine to remove links to the web pages of a Spanish daily newspaper from the list of results. 196. In this new context, in addition to the right to respect for private life, the national courts and authorities find support in the right to the protection of personal data, which in some legal systems has become a self-standing right (see the findings of the High Court of England and Wales and the Spanish Constitutional Court – paragraphs 102 and 107 respectively above). According to a different approach, in the specific case of requests for news publishers to alter press articles, the “right to be forgotten” can be based only on the protection of the right of personality, which is thus to be distinguished from the right to informational self-determination, the latter being linked to the protection of personal data (see the “Right to be forgotten I” judgment of the German Federal Constitutional Court – paragraph 114 above). The Belgian domestic courts examining the present case did not base the “right to be forgotten online” on the European or domestic provisions concerning the protection of personal data (see, in particular, paragraph 37 above). 197. For its part, the Court has examined only a handful of cases concerning requests for the removal or alteration of news articles stored in digital archives. In those cases, brought under Article 8 of the Convention, the Court defined the applicants’ interests as pertaining to the protection of their reputation, with the concept of the “right to be forgotten” being mentioned only recently, in the last of the cases listed in this paragraph. On each occasion the Court considered that the national courts, in rejecting the applicants’ requests, had struck a fair balance between freedom of expression and the public’s right to have access to the information on the one hand, and the applicants’ right to protection of their reputation on the other. (a) In the case of Węgrzynowski and Smolczewski (cited above), two lawyers complained that a newspaper article that was damaging to their reputation continued to be accessible to the public on the newspaper’s website. The lawyers requested the removal of the article, which alleged that they had made a fortune by assisting politicians in dubious business deals. The Polish courts, ruling on an earlier defamation action, had held that the article in question was based on insufficient information and was in breach of the rights of the persons concerned. In this judgment the Court held, in particular, that the Internet, which was an information and communication tool particularly distinct from the print media, serving billions of users worldwide, was not and potentially would never be subject to the same regulations and control. Therefore, the policies governing the reproduction of material from the print media and the Internet might differ. The rules concerning the latter undeniably had to be adjusted according to technology’s 67