HONOR 3374 Lecture 10: European Union vs US Privacy
Document Summary
European union views personal data as akin to a property right that is owned by the subject, whereas the us does not believe this: europe generally values privacy interests over free speech. Us values free speech over privacy (generally: europe requires express consent. Us has implied consent: europe recognizes the right to forget . Us recognizes the right to forget only in limited circumstances. Europe can remove search engine links to an article if it"s inaccurate, inadequate, irrelevant or excessive. : the article remains on the news site. United states; first amendment protects freedom to speak and publish: california eraser laws, expungement laws. Removes crimes from records (not news stories) Examples: bank hack (your bank is hacked) Europe; the company with the data breach must notify central authority and the subject of the breach within 3 days. Us; action requirements vary between states: monitoring online use.