Comparing Privacy Regimes: Federal Theory and the Politics of Privacy Regulation in the European Union and the United States

摘要: This article draws on federal theory to analyze the dynamics of crafting a privacy regime in European Union and United States. Three dimensions policy domain are analyzed: how was framed, activated, instruments used. The main finding is that despite obvious differences choice specific instruments, strikingly similar regulatory dynamic framing can be detected. Two conclusions drawn: first, reveal novel insights politics regulating privacy, especially relation new technologies counter terrorism measures. Second, applying comparative research design EU policy-making help explain many its apparent empirical puzzles.