Paddling in unison or just paddling? International trends in reforming information privacy law

摘要

The existing paradigms governing the management of personal data globally are under pressure from rapid technological and social change. This article examines recent proposals for modernizing information privacy law in the USA, the European Union, Australia and New Zealand. It finds significant areas of commonality and critically explores points of difference, notably innovations such as the de-coupling of previously linked privacy principles, dichotomies between consumer-facing companies and third parties and new rights such as the right to be forgotten and to erasure, the right to data portability, privacy by design and default and privacy impact assessment. The article argues that the proposals ought to draw on each other's strengths.