The first section of this paper examines the historical differences that have led to the American approach to privacy and the European approach to privacy. The second section will examine the current U.S. model, and the third section will examine the EU model. Next, the fourth section will compare and contrast the two models. Finally, the last section will argue that the U.S. should have a regulatory agency and describe how that should look and run.
In the Middle: Creating a Middle Road Between U.S. and EU Data Protection Policies,
32 J. Nat’l Ass’n Admin. L. Judiciary
Available at: http://digitalcommons.pepperdine.edu/naalj/vol32/iss2/10