Fordham International Law Journal
The variation and complexity of national data privacy rules pose significant challenges for international data flows. Data protection laws range from ad hoc narrow legal rights, like those found in the United States, to comprehensive fair information practice statutes like those found in Europe. Because data processing frequently occurs across national borders, multiple data protection laws might apply simultaneously to international data flows. At the same time, data protection regimes may prohibit the circumvention of national standards by processing personal information at a foreign site. Global information processing thus presents a data controller with important burdens and obstacles related to compliance with varying standards and procedures.
Joel R. Reidenberg,
The Simplification of International Data Privacy Rules, 29 Fordham Int'l L.J. 1128 (2005-2006)
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