Toronto Metropolitan University
Browse

Privacy Law in the United States, the EU and Canada: The Allure of the Middle Ground

Download (437.82 kB)
journal contribution
posted on 2023-03-07, 19:45 authored by Avner LevinAvner Levin, Mary Jo Nicholson

Privacy and personal information are regulated differently in the European Union (EU), the United Sates (US) and Canada. The EU and Canada centrally supervise the private sector's use of personal data, whereas the US regulation of the private sector is minimal. These differences emanate from distinct conceptual bases for privacy in each jurisdiction. In the US, privacy protection is essentially liberty protection, i.e. protection from government. For Europeans, privacy protects dignity or their public image. In Canada, privacy protection is focused on individual autonomy through personal control of information. We propose the Canadian model as a conceptual middle ground between the EU and the US, as a basis for future American privacy protection.

History

Language

English

Usage metrics

    Lincoln Alexander School of Law

    Licence

    Exports

    RefWorks
    BibTeX
    Ref. manager
    Endnote
    DataCite
    NLM
    DC