A Guide to Litigating Identity Systems PART ONE: THE RIGHT TO PRIVACY AND NATIONAL IDENTITY SYSTEMS 21. A common theme of all major pieces of national jurisprudence analysing the rights implications of national identity system is an analysis of the systems’ impacts on the right to privacy.33 As articulated in the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, the right to privacy is a fundamental right that protects individuals from arbitrary interferences with their privacy, family, home, and correspondence.34 22. The right to privacy is also enshrined in various other regional human rights instruments, including the European Convention on Human Rights, the American Convention on Human Rights, the Arab Charter on Human rights, and the Association of Southeast Asian Nations Human Rights Declaration. Furthermore, at a national level over 130 countries have constitutional statements regarding the protection of privacy.35 33 See, eg Madhewoo v. The State of Mauritius and Anor, 2015 SCJ 177 http://ionnews.mu/wpcontent/uploads/2015/05/Biometric-ID-Card_Madhewoo-vs-State.pdf at 23; Aadhaar Judgment, Justice K.S. Puttaswamy and Another v. Union of India and Others, Writ Petition (Civil) No. 494 of 2012 & connected matters, ¶ 29 of dissent (2018); Opinion of Justice Sykes, Julian J. Robinson v. The Attorney General of Jamaica, Claim No. 2018HCV01788, ¶ 174 (2019). 34 Privacy International, What is Privacy?, https://privacyinternational.org/explainer/56/what-privacy (retrieved 19 December 2019). 35 Privacy International, What is Privacy? 16