Abstract

The U.S. and Europe exhibit very different approaches to information privacy—a condition of limited access to identifiable information about individuals—from both regulatory and managerial perspectives. Grounded in different cultural values and assumptions about the meaning of privacy (a "human rights" issue in Europe versus a contractual issue in the U.S.), these differences have led to regulatory and managerial conflicts. In this article, the differences between the two approaches are explored. U.S. corporations would be well served to embrace some of the premises of the European perspective. However, the U.S. would be poorly served by the creation of a federal regulatory structure such as some commonly found in Europe.