legal right to privacy. United Kingdom In the United Kingdom, it is not possible to bring an action for invasion of privacy. An action may be brought under another tort (usually breach of confidence) and privacy must then be considered under EC law. In the UK, it is sometimes a defence that disclosure of private information was in the public interest. There is, however, the Information Commissioner's Office (ICO), an independent public body set up to promote access to official information and protect personal information. They do this by promoting good practice, ruling on eligible complaints, giving information to individuals and organisations, and taking action when the law is broken. The relevant UK laws include: Data Protection Act 1998; Freedom of Information Act 2000; Environmental Information Regulations 2004; Privacy and Electronic Communications Regulations 2003. The ICO has also provided a "Personal Information Toolkit" online which explains in more detail the various ways of protecting privacy online. United States Although the US Constitution does not explicitly include the right to privacy, individual as well as locational privacy may be implicitly granted by the Constitution under the 4th Amendment. The Supreme Court of the United States has found that other guarantees have penumbras that implicitly grant a right to privacy against government intrusion, for example in Griswold v. Connecticut and Roe v. Wade. Dobbs v. Jackson Women's Health Organization later overruled Roe v. Wade, with Supreme Court Justice Clarence Thomas characterizing Griswold's penumbral argument as having a "facial absurdity", casting doubt on the validity of a constitutional right to privacy in the United States and of previous decisions relying on it. In the United States, the right of freedom of speech granted in the First Amendment has limited the effects of lawsuits for breach of privacy. Privacy is regulated in the US by the Privacy Act of 1974, and various state laws. The Privacy Act of 1974 only applies to federal agencies in the executive branch of the federal government. Certain privacy rights have been established in the United States via legislation such as the Children's Online Privacy Protection Act (COPPA), the Gramm–Leach–Bliley Act (GLB), and the Health Insurance Portability and Accountability Act (HIPAA). Unlike the EU and most EU-member states, the US does not recognize the right to privacy of non-US citizens. The UN's Special Rapporteur on the right to privacy, Joseph A. Cannataci, criticized this distinction. Conceptions of privacy Privacy