Accountability as the Basis for Regulating Privacy: Can Information Security Regulations Inform Privacy Policy?

This paper by Mary Culnan of Bentley University argues that the current approach to regulating privacy based on “notice and choice” or “harm” is not effective and needs to be revisited. The paper proposes augmenting the current approach with new regulations based on accountability where firms are delegated responsibility to develop risk management programs for privacy tailored to their individual circumstances.

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