EIRP Proceedings, Vol 7 (2012)

EU and US Data Protection Reforms. A Comparative View

Gabriela Zanfir


This research makes a comparative analysis of two significant reform projects in data protection legislation, proposed in early 2012 in the EU and the US, in order to identify the common philosophies and also the main differences between them. Its outcomes are important as transatlantic data transfers are exponentially increasing and their main actors need to know what to expect from both legal regimes. The paper builds on a ground zero, as both reform projects were made public in late January – respectively late February, so such a comparison can only refer to researches made prior to the announcements regarding the general concepts of privacy and data protection in the European and American view. The main method employed is comparative observation. The results show that EU and US legislations start using the same language regarding data protection law – by the legal definitions proposed and main principles implemented, while still keeping significant differences. Academics and researchers will have a starting point for future comparative analyzes in a legal field which enjoys a lot of attention from lawmakers all over the globalized world. The paper focuses on very recent legal developments, which need throughout analysis in order to make them functional in practice.


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