Once again, the Sunday New York Times is running a privacy-related story. This week, Eric Dash discusses the differences between the US and Europe, highligting the legal, business and cultural differences between the jurisdictions:
Europe Zips Lips; U.S. Sells ZIPs - New York Times"Why [are all these privacy/security incidents] happening here, and not, say, in Britain, Germany or France? One reason may be that every other Western country has a comprehensive set of national privacy laws and an office of data protection, led by a privacy commissioner.
The United States, by contrast, has a patchwork of state and federal laws and agencies responsible for data protection.
"In Europe, the question has been settled: citizens have strong legal rights," said Joel R. Reidenberg, a Fordham University law professor who is an expert on international data privacy rules. "In the United States, we basically have a mess, and we are still trying to sort it out."
More fundamentally, these two systems for dealing with data arise from a cultural divide over privacy itself. In broad terms, the United States looks at privacy largely as a consumer and an economic issue; in the rest of the developed world, it is regarded as a fundamental right...."
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