Daily DashboardEuropean Data Protection Digest

Cultures Collide on Privacy

ONLINE PRIVACY—EU & U.S.

March 1, 2010

The New York Times explores the fundamental differences between American and European attitudes toward privacy--a topic that has become front of mind for many in the days following last week's conviction of three Google executives in an Italian court. "Americans to this day don't fully appreciate how Europeans regard privacy," says Jane Kirtley of the University of Minnesota. The European framework, describes Google lawyer Nicole Wong, sees privacy as a human-dignity right. "As enforced in the U.S., it's a consumer-protection right," Wong adds. Indiana University Professor Fred Cate explains how the origins of Europe's privacy protectiveness--the response to totalitarian regimes' myriad privacy-intrusive methods for maintaining power--differentiate it from America's, where free speech often trumps privacy. Meanwhile, a University of Michigan professor offers an alternate, less privacy-centric theory on why the Italian court was keen to convict the Google executives. (Registration may be required to access this story.)
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