关键词: 个人信息, 个体性, 社会性, 个人主义, 社会公益

Abstract: The concept, connotation and nature of personal information in modern society are emphasized based on the current situation of personal information protection The individuality and sociality shown in the formation of personal information divide it into two categories: inherent information and derivative information Meanwhile, the perspective of comparative law is introduced to analyze the means and modes of personal information protection in the US and Germany, and to compare their characteristics and commonalities, in order to provide reference to the construction of personal information protection mode in China We should firmly take hold in China’s specific national conditions, attach importance to China’s historical and cultural background, social values and legal system, comprehensively consider the balance of interests between personal information security and social public security, and explore the personal information protection mode that best fits the local legal culture.

Key words:  personal information, individuality, sociality, individualism, social welfare