Europe and US have different approaches to protecting privacy of personal data

[Commentary] Laws are very different when governments consider something a right and not a privilege. Healthcare is one example. Privacy is another. European officials made clear recently that when it comes to protecting people's personal information, the burden is on businesses, not consumers, to do the heavy lifting.

A new data-privacy rule, to apply to more than 500 million people in 28 countries, will be put into effect by early 2017. Among other provisions, it will guarantee Europeans the right to have companies delete information about them that's no longer relevant and require businesses to inform regulators within three days of any data breach Contrast that with the approach in this country, where business interests uniformly come first. For example, corporate lobbyists have made sure that consumers have to opt out from having their personal data shared, rather than require companies to seek customers' upfront approval. Every expert I spoke with said the starting point for any discussion of privacy rights in America begins with the question of how it will affect business. The Europeans, they said, began their rule-making discussion four years ago with an understanding that privacy is a human right.