A fundamental difference between the EU and the US' approach to data privacy is the question of ownership, law and privacy experts told a group of European journalists in New York last week.
In Europe, data protection is granted even after the consumer has passed on the data, while in the US, the company's understanding is that once it has the information, it can do whatever it wants with it. "When we explain to a US company for the first time how data privacy laws work in Europe, they say 'you must be kidding?' It takes a few years to acclimate to that," said privacy lawyer Lisa J Sotto from Hunton & Williams, a New York based law firm.
Ms Sotto argued that the cultural difference between the two continents stems from history. "Here, privacy is not a fundamental human right, instead it's a consumer protection interest. In Europe, where people could have been put to death because of their data, here they were marketed to to death," she said.
For more: EUobserver / EU privacy rules changing US companies
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