Contrasting European and American Approaches to Privacy in Electronic Markets: Property Right versus Civil Right

  • Detlev Zwick, Nikhilesh Dholakia
  • Electronic Markets, February 2001, Taylor & Francis
  • DOI: 10.1080/101967801300197034

Privacy policies - on two sides of the Atlantic

What is it about?

EU has always been wary and vigilant about protecting the private data about its residents and citizens. USA has not bothered, and in 2017, widened the "privacy chasm" vis-a-vis EU. This paper lay out the key issues in a succinct way.

Why is it important?

While we wrote this piece at the beginning of the 21st century, the contrast of American and European approaches to electronic privacy continues well into the second decade of the 21st century. This article provides important background to the ways US and EU approach online privacy, and therefore cybersecurity.

Perspectives

Dr Nikhilesh Dholakia
University of Rhode Island

With swiftness and stealth, on March 28, 2017, US Congress and Senate passed a bill that destroys all pretenses in USA (the few that existed) for safeguarding the private data of individuals… data that we generate routinely as electronically connected citizens, consumers, and community members. The data fields have been now flung open for all manners of exploitation, including possibly to dangerous assaults. These headlines appeared within 48 hours of this bombshell law: Scientific American: https://www.scientificamerican.com/article/data-privacy-is-trumps-fcc-redefining-public-interest-as-business-interest/ CNN: http://money.cnn.com/2017/03/28/technology/house-internet-privacy-repeal/ Huffington Post: http://www.huffingtonpost.com/entry/us-eliminating-rules-on-data-privacy-poses-a-serious_us_58db7592e4b0487a198a55a2 Folks, it is time to revisit the work that Detlev Zwick and I started at the turn of this century. The concerns we had raised are in the smack center of public discourse in 2017. We had started pointing out the big gap in privacy protection between EU and USA, as early as about 2000. The new bill in USA makes this gap a giant chasm. Just as on the issues of environmental protection, USA has ceded leadership to China, on the issue of data privacy protection of individuals, the onus is now on EU to save the world. It would be wonderful, for example, if EU could extend its privacy protection umbrella to all those non-EU folks who deal with EU folks via electronic means. My bet is that this would likely cover half the population of the planet.

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http://dx.doi.org/10.1080/101967801300197034

The following have contributed to this page: Dr Nikhilesh Dholakia