“For almost two decades, a myth has been circulating that the European Union’s approach to privacy and data protection is ‘stricter’ than the sectorial approach the U.S. employs,” writes Jenner & Block Partner Mary Ellen Callahan, CIPP/US. In a column for The Lawyer, Callahan notes “the two regions' approaches have more in common than the myth would suggest.” Both approaches are grounded in the Fair Information Practice Principles, she writes, adding, “Although differences in emphasis, interpretation and implementation exist, they provide an invaluable lens through which governments and companies can analyze whether they are employing appropriate privacy protections.”
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