The United States and European economies are both information economies, however, they have different approaches in protecting personal information. This study examines in as much detail as possible, the relevant privacy laws in the two economic regions. The Europeans have a comprehensive legislation regulating personal information that vests considerable control on the data subject. Europeans characterize personal data as a fundamental human right. Americans, on the other hand, protect personal information by legislating for specific industries as the need arises and do not recognize privacy of personal information as a fundamental right. This study concludes the European approach is preferable, because it takes cognizance of the autonomy and dignity of the individual.
Obasi, Emeka B., "Privacy and Personal Data Protection in the Information Age: A Comparative Evaluation" (2002). LLM Theses and Essays. 320.