A Global Perspective of Privacy Protection Practices (original) (raw)

A Comparative Study of Privacy Protection Practices in the US, Europe, and Asia

International Journal of Information Security and Privacy, 2018

This article describes how national and international companies in the US and Europe, as well as newly industrialized countries such as China and India, are striving to gain consumer trust by offering visible and meaningful Privacy Protection Policies (PPP) on their websites. This article deploys large sets of data and descriptive indicators to compare and contrast the extent of the visibility, specificity, and lucidity of privacy policies posted by interactive companies on the Internet. Examining about 2000 Interactive companies in the USA, Europe, and Asia provides a measure of divergent responses to the growing demand for privacy protection. The results of this comparative study should help interested readers from the business world, academics, and administrations get a grasp of the extent of efforts by international corporations to protect personal information privacy in an increasingly global economy.

The Internationalisation of Information Privacy: Towards a Common Protection

The conventional view of privacy, at least shared among privacy scholars, is that privacy is a rather culture—dependent issue and would be interpreted much differently in various jurisdictions. Though this is pretty true in the pre—digital age, the scenario may have been under considerable change due to the fact of the creation of new social spheres and life experience by numerous new technologies in the digital age. The popular use of the Internet, portable devices, smart phones, geographical location devices, smart home facilities, as well as the accompanied exploitation of big data collected from such devices, create a new living environment or life structure in which personal data become highly valuable in market economy and critical for personal development. Not only our perception of privacy needs update in order to follow the new reality, but also people will acquire more commonly—shared life experience, sensibility and consciousness of one perspective of privacy: information privacy. Such commonalities consequent to living in the information age against the backdrop of escalating privacy invasion, all contribute to a more commonly accepted concept of information privacy; therefore the internalization or universalization of information privacy that is attributed to a more common life structure based on information digitization and connected networks and has long run impacts on our life and laws. This short article intends to explore this new tendency, namely the internalization (or universalization) of information privacy, in both life realities and different legal systems. It will first discuss what and how the digitalization of human life has contributed to a more shared life experience among human beings based on the increasing connectivity, and how this further enables or generates a common perception of information privacy across the world. Second, the article will explore how the recent legal developments in both domestic laws and international laws adapt to the new life realities beyond cultural difference and political divergence. For this purpose, definitions of information privacy are compared from different jurisdictions, International policy and law documents analysed, and various court verdicts discussed, showcasing the internalization tendency of information privacy. Last, the article proposes a coherent protection of information privacy in International law to remedy the present gridlock in improving Internet Governance after Snowden's revelations.

A multinational study on online privacy: Global concerns and local responses. New Media & Society

This study surveyed 1261 internet users from five cities (Bangalore, Seoul, Singapore, Sydney and New York) to examine multinational internet users' perceptions and behavioural responses concerning online privacy. It identified a set of individual-level (demographics and internet-related experiences) and macro-level factors (nationality and national culture), and tested the extent to which they affected online privacy concerns and privacy protection behaviours. The results showed that individual differences (age, gender and internet experience), nationality and national culture significantly influenced internet users' privacy concerns to the extent that older, female internet users from an individualistic culture were more concerned about online privacy than their counterparts. The study also identified three underlying dimensions of privacy protection behaviour -avoidance, opt-out and proactive protection -and found that they distinctly related to the individual and macro-level factors. Overall, the findings highlight the conditional and multicultural nature of online privacy.

A comparative study of online privacy regulations in the U.S. and China

Telecommunications Policy, 2011

Online privacy seeks to protect the identity of individuals who use the internet to collect information or express opinions. However, given the proliferating vehicles through which one's identity can be ascertained, the question remains as to what policies can most effectively protect personal identity. This paper explores the similarities and differences with online privacy regulation in the United States and China. The scope of privacy measures examined here ranges from government to personal levels, from communication and finance to personal records, for adults and children. As might be expected in a democracy, American legislative initiatives are more comprehensive and far-reaching than those of their Chinese counterparts. In China, there was until recently no specific right of privacy specified in dedicated legislation, with privacy having been instead protected under the right of reputation in the Civil law. Policy implications stemming from these competing models are evaluated. Study findings underscore the notion that privacy should be a universally established individual right, and that both countries are moving-at least in rhetorical terms-to strengthen it as such.

Globalization and Data Privacy

International Journal of Information Security and Privacy, 2000

Global organizations operate in multiple countries and are subject to both local and federal laws in each of the jurisdictions in which they conduct business. The collection, storage, processing, and transfer of data between countries or operating locations are often subject to a multitude of data privacy laws, regulations, and legal systems that are at times in conflict. Companies struggle to have the proper policies, processes, and technologies in place that will allow them to comply with a myriad of laws which are constantly changing. Using an established privacy management framework, this study provides a summary of major data privacy laws in the U.S., Europe, and India, and their implication for businesses. Additionally, in this paper, relationships between age, residence (country), attitudes and awareness of business rules and data privacy laws are explored for 331 business professionals located in the U.S and India.

Internet Privacy Policies of the Largest International Companies

Journal of Electronic Commerce in Organizations, 2006

This article is a review of Internet privacy policies of the world's largest companies. The report begins with a background on the right to privacy and privacy issues arising out of Internet usage. Attempts to regulate Internet privacy and self-regulatory effectiveness also are reviewed. The methodology for this study is to update and extend Internet privacy analysis by analyzing Web sites of the largest international companies (Forbes International 100) for inclusion of fair information practices. In addition, a collection of consumer-centered practices is defined and studied. The general finding is that within Forbes International 100, fair information practices and consumer-centered privacy policies are not being followed closely. It is also found that large U.S. firms are more likely to publish a privacy policy on their Web site. Finally, if a large international firm does publish a privacy policy on its Web site, the level of compliance with fair information practices and consumer-centered policies is not significantly different between U.S. and non-U.S. firms. Implications of the study for researchers and practitioners are reviewed.

An International Comparison of Approaches to Online Privacy Protection

Information and Communication Technologies in Tourism 2005, 2005

The Web provides unprecedented opportunities to implicitly and explicitly gather highly detailed data about website visitors, resulting in a real and pressing threat to privacy. Approaches to protecting this personal data differ greatly throughout the world. Most countries follow one of two diametrically opposed philosophies -the self-regulation approach epitomized by the United States, or the comprehensive omnibus legislative approach mandated by the European Union. This paper contrasts these approaches, performs an international comparative analysis of the current situation and highlights how the legislative approach is being adopted as the de-facto standard. The use of trust marks as an alternative solution is also discussed, the effectiveness of each approach examined and the implications for tourism firms highlighted.

Privacy Protection: A Tale Of Two Cultures

2012

The paper provides a novel and critical analysis of privacy as an instrumental notion within social and cultural contexts. The argument suggests there is much utility in a novel multiple-perspective approach to the study of privacy in a socio- legal context. It questions our assumptions about privacy by looking to a differing privacy culture - that of the India. It examines the Indian perception of privacy based on India's cultural values and offers an explanation for why India's concept of privacy is beyond the often dominated public-private dichotomy and why it has implicitly or explicitly affected the agenda for privacy theory by placing some issues in the limelight while leaving others backstage. The importance of the argument is due to its critical assessment of the current European approach (from the EC, ECJ and ECHR) where privacy is regarded as an inalienable right with a concrete psychological foundation. I argue that privacy interests are far more extensive and deeper than the European definition which can at best capture only some of the issues which require elucidation when we litigate over privacy.

A Study of South Asian Websites on Privacy Compliance

IEEE Access, 2020

Privacy laws in South Asian countries are still at a nascent stage. Therefore, South Asian websites are susceptible to user privacy violation. This paper presents an assessment of website privacy policies from 10 sectors in the three largest South Asian economies, namely, India, Pakistan, and Bangladesh. Using a manual qualitative analysis on a dataset of 284 popular websites, we assessed the policies based on accessibility, readability, and compliance with 11 privacy principles. Our findings show that overall, the privacy statement accessibility, and privacy compliance of websites from the three countries is low especially in the education, healthcare, and government sectors. Readability is quite low for websites in all 10 sectors of the three countries. Privacy compliance in each country is the highest for the principles of data processing and third-party transfer, whereas it is the lowest for protection of children's data, data retention and portability. Indian websites performed comparatively better amongst the three countries on all three metrics, followed by Pakistan, and Bangladesh. Based on our results, we provide recommendations involving all stakeholders (i.e., website owners, privacy regulators, and users) to help improve privacy protection of user data in South Asia.