In a recent blog entry on EDiscoveryMap, Monique Altheim highlights some of the differences between EU and U.S. approaches to privacy regulation, contrasting the differences between yesterday’s Senate hearing on consumer privacy and a talk given by Viviane Reding, Vice President of the European Commission, Commissioner for Justice, Fundamental Rights and Citizenship, “The Review of the EU Data Protection Framework.”
While EU and U.S. privacy advocates seem to be at arm’s (pond’s?) length on the issue of a “right to be forgotten,” there are also significant differences in other aspects of how privacy is viewed and embodied within the laws and respective cultures. In many respects, American privacy advocates like myself are probably more comfortable with the European approach of viewing privacy as a fundamental human right. Instead, we find ourselves poring through legal decisions looking for any glimmer of recognition of any kind of right to privacy.
Read Monique’s commentary on EDiscoveryMap. It may help you get a better sense of the differences in our respective frameworks.
There is a mentality in the U.S. that usually resists following Europe’s lead. Maybe it’s a throwback to our revolutionary roots, but when it comes to privacy, the EU is way ahead of us in some respects.