In addition to requiring the state to refrain from arbitrary interferences with the protected rights, Article 81 requires the state to take positive steps to secure or protect the enjoyments of those rights2 including, for example, an obligation to put in place systems to protect an individual's private life from interference by non-state entities such as the media3. The extent of the obligations may vary according to factors such as the nature of the right at issue, the importance of the right for the individual and the nature of the activities involved4. The state is also under a positive
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