Hello all

Brief comment from Germany, personal rather than the corporate position...

It could be argued that the UK intepretation of the Directive is weaker than most...
- the german speaking countries have strong legislation (including Switzerland- obviously not directive based, but think of all those bankers..) Austria is also strict. Nordics strong see below, spanish are big on fines....

- Sweden  see http://www.ejeisa.com/nectar/update/stories/2000020202.htm and the SABRE case  in 1995, the Swedish Data Inspection Board ruled that American Airlines, Inc. was prohibited from transferring personal data on Swedish passengers to the United States for processing using its SABRE travel information network. The Swedish Data Inspection Board decision to block American Airlines's transfer of personal data to the United States was based on the fact that the United States had not acceded to the Council of Europe Convention for the Protection of Individuals with regard to automatic processing of personal data, and thus failed to provide adequate protection to personal data. In addition, American Airlines proposed to transfer
sensitive personal data, including data on religious beliefs (for the purpose of honoring special meal requests) and disability (for the purpose of providing assistance at the airport). Under Swedish law, such sensitive personal data can
only be processed with the individual's informed consent.

quite a useful comparative analysis  at http://www.privacyinternational.org/survey/index.html#news Interesting general privacy related stuff...

It is probably correct to say that most of continental europe is more privacy aware. Data Protection figures relatively prominently in IT discussions(can derail software projects etc) Many public sector software solutions require data protection compliance validation before purchase....), and many citizens have been aware of their DP rights of years.


Cynically the directive was an attempt at a balance between the privacy focused nations (Germany, France, Austria, Nordics) and those with relatively weak privacy provisions. One of the reasons why Germany took so long to implement the directive was not fear that it was too strong, but rather not strong enough. (might explain some of the current french tardiness)

Thomas Otter

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-----Original Message-----
From: Jim Ford [mailto:[log in to unmask]]
Sent: Donnerstag, 25. September 2003 14:29
To: [log in to unmask]
Subject: Re: [data-protection] Data Protection Worldwide


No real evidence to back this up, by expect that Scandinavian
countries, esp. Sweden would have quite strict legislation. They've
had FOI for a long long time.

Jim

On 25 Sep 2003, at 11:44, Antoinette Carter wrote:

> Can anyone enlighten me as to which countries around the world have
> more strident data protection law than our own here in the UK.  The
> only examples I know of are Germany (who I understand do not allow the
> recording of telephone conversations "for training and/or evaluation"
> even if the caller has been fully informed) and of Spain (where the
> Information Commissioner is remarkably heavy-handed with fines imposed
> under DP law).  Can anybody come up with any other examples?
>
> Regards,
> Antoinette Carter
> Data Protection Officer
> British Council, 10 Spring Gardens, London SW1A 2BN
> Tel: +44 (0) 207 389 4970
> [log in to unmask]
> Creating opportunity for people worldwide
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