"The challenge now confronting the search for a right to privacy is to be able to delineate privacy interests with greater clarity and precision. Some guidance might be found in international human rights norms, especially Article 8 of the European Convention on Human Rights 32 and Article 17 of the International Covenant on Civil and Political Rights, and their associated jurisprudence. One might also undertake comparative analysis of privacy protection in national laws and constitutions A significant drawback of these strategies, however, is that conceptions of privacy rights in positive law tend to be parceled up with a certain degree of institutional legal baggage. Allied to the effect of encountering multiple and inconsistent legal definitions, this may serve to confuse in many respects, at the same time as clarifying other matters, which in the aggregate does not necessarily advance the cause of enlightenment. Fortunately help is at hand, in the shape of some excellent academic philosophy and legal writing on privacy interests and rights. In particular Ruth Gavison has explained the interests protected by a right to privacy in terms of limiting a person's accessibility to others. This seems to me to encapsulate the kernel of the idea we require: Our interest in privacy . . . is related to our concern over our accessibility to others: the extent to which we are known to others, the extent to which others have physical access to us, and the extent to which we are the subject of others' attention. This concept of privacy as a concern for limited accessibility enables us to identify when losses of privacy occur. Gavison breaks down the interest in limited accessibility into three further “irreducible elements” of privacy, “which she calls “secrecy, anonymity, and solitude”: As a methodological starting point, I suggest that an individual enjoys “perfect” privacy when he is completely inaccessible to others. This may be broken down into three independent components: in perfect privacy no one has any information about X, no one pays any attention to X, and no one has physical access to X. . . . A loss of privacy occurs asothers obtain information about an individual, pay attention to him, or gain"