EUROPEAN UNION DATA PROTECTION DIRECTIVE
3 WAYS IN WHICH US AND EU PRIVACY REGIMES DIFFER
Although privacy rights of individuals are protected within both the EU and the US,
the way in which such privacy rights are protected differ substantially:
1.
- In Europe: The Directive is the single source of legislation that applies to all member states and covers all personal data. It applies across the board to any organisation processing any type of personal data (ie not just limited to marketing data or financial data).
- In the US: Privacy laws are a patchwork of federal and state laws which deal with industry specific privacy issues (eg financial or medial information, or information used for marketing purposes). Not all personal data are covered.
2.
- In Europe: The Directive grants individuals a general right of access to their personal data. There are some limited exemptions, but generally an individual is entitled to see any personal data that are processed about him or her for any purpose.
- In the US: There is a limited right of access, mainly in relation to specific areas, such as consumer reports, but it is not a general right.
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