Home → Magazine Archive → February 2016 (Vol. 59, No. 2) → In Privacy Law, It's the U.S. vs. the World → Abstract

In Privacy Law, It's the U.S. vs. the World

By Tom Geller

Communications of the ACM, Vol. 59 No. 2, Pages 21-23

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Google is forced to wipe a Spanish citizen's past financial troubles from its records. The Belgian Privacy Commission tells Facebook it must "bend or break" to abide by the country's privacy laws. A plaintiff presses privacy cases against Facebook in both Austrian and European courts.

In each instance, national privacy laws collide with the international nature of the Internet, and with American business expectations. Cross-border issues of the online world are not new, of course: the European Data Protection Directive at the center of many such cases was enacted in 1995, and online jurisdiction cases go back at least as far (the 1996 U.S. vs. Thomas decision affirmed a California bulletin board system (BBS) operator must obey "community standards" for Tennessee subscribers). Yet few cases have cited the European law to prosecute U.S. companies.


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