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A new study comparing European and U.S. corporate privacy practices reveals that while European companies impose tighter restrictions on the sharing of sensitive personal data, U.S. companies overall provide a higher level of privacy.
Sponsored by global law firm White & Case LLP as part of its annual Global Privacy Symposium, this 'Benchmark Study of European and U.S. Corporate Privacy Practices' was conducted by the independent privacy think-tank Ponemon Institute. The study confidentially surveyed 47 U.S. and European multinational companies on eight privacy practices, including: privacy policy; communications and training; privacy management; data security methods; privacy compliance; choice and consent; cross-national standards; and redress.
The survey revealed that European companies are much more likely to have privacy practices that restrict or limit the sharing of customer or employees' sensitive personal information, and are also more likely to provide employees with choice or consent on how information is used or shared. But the research also showed that U.S. companies are engaging in more security and control-oriented compliance activities than their European counterparts. As a result, contrary to conventional wisdom, U.S. corporations scored higher in five of the eight areas of corporate privacy practice.
This article highlights how copyright law in the United Kingdom differs from U.S. copyright law, and points out differences that may be crucial to entertainment and media businesses familiar with U.S law that are interested in operating in the United Kingdom or under UK law. The article also briefly addresses contrasts in UK and U.S. trademark law.
The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
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