Abstract
The thesis presents a retrospective analysis of the representative action legal mechanism in order to identify the type of legal figure adopted in the European General Data Protection Regulation. The study focuses on the development of class action in the US, where it has evolved the most, and then it makes a comparative analysis between the US system and Article 80 of the recent European GDPR, taking into account the development in four member states (France, Belgium, Spain and Germany). This study clearly establishes the significant differences between the US and the European representative action model and identifies the challenges that the legal figure has with respect to data protection. The latter will be very useful for lawmakers, since by identifying the challenges, more suitable standards can be created for the correct application of the collective redress mechanism in the field of data privacy.