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EU and US Data Protection Reforms. A Comparative View

Keywords: privacy , EU-US data transfers , legal definitions , privacy principles

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Abstract:

This research makes a comparative analysis of two significant reform projects in data protectionlegislation, proposed in early 2012 in the EU and the US, in order to identify the common philosophies andalso the main differences between them. Its outcomes are important as transatlantic data transfers areexponentially increasing and their main actors need to know what to expect from both legal regimes. Thepaper builds on a ground zero, as both reform projects were made public in late January – respectively lateFebruary, so such a comparison can only refer to researches made prior to the announcements regarding thegeneral concepts of privacy and data protection in the European and American view. The main methodemployed is comparative observation. The results show that EU and US legislations start using the samelanguage 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 futurecomparative analyzes in a legal field which enjoys a lot of attention from lawmakers all over the globalizedworld. The paper focuses on very recent legal developments, which need throughout analysis in order tomake them functional in practice.

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