A Comparative Study of Data Privacy Models in Europe and the United States

In a world where personal data can easily be extracted from the simplest of online transactions or actions in general, the need for sufficient data protection protocols, laws and regulations has never been more dire. In past years, the internet was at its infancy which led countries to adapt or establish laws that did not really protect the personal data of its residents from internet attacks, scams etc. The rapid growth of the internet has led countries to expand on their previous laws and regulations or to create new ones. The differences of these laws and regulations is the main scope of this thesis.
This thesis will begin with an overview of the previous law in Europe (Data Protection Directive) and will continue with an overview of the law that replaced the DPD, the General Data Protection Regulation while providing a comparison between the two laws. The thesis then will move on with the different state laws in the United States. In both the overview of the European laws and the one of the United States, the format will be the same with minimal to no divergence. There will be some introductory remarks about the law such as the date it was signed into law and then we will list the rights of the data subjects who are subject to this law. We will finish each law by listing the responsibilities and obligations of the controller towards the data subjects.
The final part of this thesis will concern the differences between European and US data protection laws and regulations. These differences range from cultural differences regarding who these laws favor most to whether these laws are consent based or not to technical differences such as range of application, lawful basis etc.