RULE, James B
La protection des données personelles aux État-Unis : la réaction à la directive européenne - Paris : IIAP, janv./mars 1999
The tensions which exist between American law and Community law on data protection reveal less a difference in starting position as in operation and institutional context. The conflict lies in the prohibition upon exporting personal data to countries which do not have an adequate level of protection. It is indisputable that the United States does not yet satisfy this critera. While no legislative reform programme is envisaged, a solution may be found in the application of familiar principles such as self-regulation, thus allowing businesses or the commercial sector to fulfil the Community requirement. However, to this day self-regulation has yet to really prove itself in this area
La protection des données personelles aux État-Unis : la réaction à la directive européenne - Paris : IIAP, janv./mars 1999
The tensions which exist between American law and Community law on data protection reveal less a difference in starting position as in operation and institutional context. The conflict lies in the prohibition upon exporting personal data to countries which do not have an adequate level of protection. It is indisputable that the United States does not yet satisfy this critera. While no legislative reform programme is envisaged, a solution may be found in the application of familiar principles such as self-regulation, thus allowing businesses or the commercial sector to fulfil the Community requirement. However, to this day self-regulation has yet to really prove itself in this area
