Comparing US and European Privacy Laws

The (US) Electronic Communications Privacy Act of 1986


The European Union Directive on Data Protection of 1995

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After researching just the basics of the two laws and their ramifications, I realize it is no wonder the average citizen has little knowledge, if any, about these laws and how they are personally affected by them.

The more I read, the more I realized it can be pretty confusing for the average person. If you are like me, you find it impossible just to keep up with all the privacy statements that come from credit card companies, doctors, and most everyone we do business with! To think about wading through this without a lawyer along for the journey is mind-boggling.

So I started with Wikipedia, just to get a feel for the subject. It is likely the most easily understood of the resources I encountered, but being a wiki, I realize I need to take it as a starting point, not equivalent to original or peer-reviewed sources.

As with most comparisons between the European Union and the US, they only take us so far. The cultural, economic, and political realities are different enough to cause both commiseration and confusion.

I came away with the reminder that we need to be aware of what our elected (and appointed) legislators are up to, and to be involved enough to hold them accountable. Most of all, we need to remember all the Y2K-reminiscent fear-mongering without indulging ourselves in a Pollyanna-like naiveté.

One Belgium-based lawyer's comparison of the European and the U.S. laws can be found at Infosec Institute.