Comparative analysis of investigative tactics of foreign countries in relation to digital data

the purpose of the article is to conduct a comparative analysis of investigative tactics of foreign countries, to determine the possibility of their adaptation to the conditions of the Russian criminal process. The author examines the legal and organizational and technical foundations of the collection, recording, storage, analysis and use of digital data in criminal proceedings using the example of the United States, Great Britain and France. The analysis showed that the priority of judicial control, documentation of procedures and expert verification of digital data are common to all three jurisdictions. At the same time, approaches differ in the degree of procedural formalization: the American model is based on constitutional guarantees of privacy and strict authentication standards, the British model is based on professional standardization and independent audit, the French model is based on high formalization and institutional centralization. The introduction of the institute of digital evidence authentication, expert certification and judicial control over access to encrypted information into the Russian legal system will help to increase the reliability and procedural security of digital evidence.

digital evidence, investigative tactics, criminalistics, criminal procedure, authentication, storage chain