According to James Q. Whitman, the vast difference between the concepts of privacy in America and Europe is that in the former, it takes the form of the right to be free from state intrusion, while in the latter, this is manifested in the protection of the right to respect and personal dignity, reputation, and informational self-determination (Halbert & Ingulli, 2011). Europeans seek to control their public image to ensure that people see them the way they want to be seen.
A European perspective on privacy, shaped by the way data was collected and used under communism and by dictators such as Franco and Hitler, is reflected in the strength of the European Privacy Directive’s protections. According to it, the information can only be used for the purpose for which it was collected and be processed with the consent of the subject or for the protection of a third party (Halbert & Ingulli, 2011). The directive severely restricts data collection on racial or ethnic origin, political opinion, religious beliefs, trade union membership, health, or sexuality (Halbert & Ingulli, 2011). It also gives Europeans the right to access and correct inaccuracies in the information collected about them.
The biggest difference from the United States perspective is the European concept of the “right to be forgotten.” A citizen can submit a request to delete personal data, in particular, a URL to a social network. Simultaneously, in the United States, consumer information may be held by the organizations that process it (Halbert & Ingulli, 2011). In contrast, Europeans have the right to revoke permission for companies to retain their personal data. In Germany, employers’ social media research is illegal, while US regulators have determined that firms do not violate privacy in this way.
Reference
Halbert, T., & Ingulli, E. (2011). Law and ethics in the business environment. Cengage Learning.