http://www.markleweeklydigest.org/2012/09/eu-and-us-eye-privacy-in-parallel.html
The article linked above adds to the comparative discussion between EU and US privacy regimes. In every conversation I can recall, Americans consider both the European and Canadian models of FIPs and Privacy by Design to be much superior to the sectoral approach here in the US. And on their face, I think this makes a lot of sense: keep the focus on the use, collection, and storage of *all forms* of personal data, rather than trying to chase down, and apply rules governing, singular instances of data abuse (e.g. mobile device IDs, GPS location, drone surveillance, etc, etc).
During a conversation the other day with a colleague, we wondered: is there actually any evidence to support the claim that the European model leads to better consumer or industry outcomes? This isn’t meant to be a normative question, but an empirical one. Are there fewer cases of medical identity theft in Europe? Are there fewer privacy intrusions? Is there less cyberstalking, tax or government fraud, or forged identification documents? Is there any evidence at all that FIPs create better outcomes?
One paper I can think of compares the effect of US and EU privacy regimes on consumer credit and debt (http://userpage.fu-berlin.de/~jentzsch/eu-vs-us.pdf). The paper finds that the EU has stronger data protection and credit reporting laws (i.e. allows less information exchange), but also less consumer debt than the US. In addition, the US, having a weaker privacy regime (i.e. allowing more information flow), has fewer national credit bureaus and that US consumers enjoy broad access to credit (which we may feel is good) — but they also suffer from more consumer debt (which we may feel is bad). While it would be unfair to characterize this as a causal model, what might be a possible explanation?: that weaker privacy regimes lead to cheaper credit, but induce more consumer debt. So on net, is this good or bad?
Of course, this is just one paper. I’d love to hear of any other empirical work on this topic.