A work in progress, works cited under development.
This paper will focus on legislation in the European Union, the United Kingdom, China, and the United States. In summary, we will be able to see some of the key differences in the various legislation, but more importantly we will be up to date on these increasingly important laws that affect the way our personal information is used around the world.
Data Protection Directive, Directive 95/46/EC and Data Protection Directive, Directive 97/66/EC
Enacted in 1995 and in 1997, these European Union directives act to harmonize member state legislation in the data protection arena.
Data Protection Act 1988, United Kingdom
Although enacted before the EU directive above, this is the main piece of legislation guiding data protection in the UK.
Data protection in China
Only relatively recently has a framework for data protection laws developed in China.
Data protection in the United States
Rather than using a central framework approach to data protection laws, the United States allows business to flourish, taking issues into account as doing so becomes necessary. Therefore, there is detailed legislation in place, but the sectors for which they are in place vary widely.
There are other statutes and regulations in place that form the framework of data protection law, but the key to note is the approach different regions around the world have taken with regard to developing data protection laws and what implications this will have for a general “right to privacy.”
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