Comparison of International Privacy Concepts

Key to international privacy concepts The table below presents a comparison of privacy concepts set out in some domestic and international privacy regulations, laws, and guidelines in relation to Generally Accepted Privacy Principles. This is for illustrative purposes only and not meant to be comprehensive. Column 1 lists the 10 principles of Generally Accepted Privacy Principles. Columns 2 through 9 lists the significant principles discussed in specific laws and regulations. The "Key to Column and Source," that follows the table identifies the source of each law and regulation compared:

Key to Column and Source

AICPA/CICA Generally Accepted Privacy Principles, May 2009.
Australia Privacy Act 1988, Privacy Act 1988, as amended, effective December 21, 2001.
Canada Personal Information Protection and Electronic Documents Act (PIPEDA), also referred to as. Bill C-6, Second Session, Thirty-sixth Parliament, 48-49 Elizabeth II, 1999-2000, assented to April 13, 2000, effective January 1, 2001.
EU Directive, European Union (EU), Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, October 24, 1995, effective October 25, 1998, as implemented in EU country-specific laws and regulations.
OECD Guidelines, Organisation for Economic Cooperation and Development (OECD), Guidelines Governing the Protection of Privacy and Transborder Flows of Personal Data, September 23, 1980.
U.S. FTC, Privacy Online: Fair Information Practices in the Electronic Marketplace, A Report to Congress, United States ( U.S.) Federal Trade Commission (FTC), May 2000.
U.S. Safe Harbor, an agreement between the U.S. Department of Commerce and the European Commission's Internal Market Directorate, approved by the European Commission July 27, 2000, open for use November 1, 2000.
U.S. United States Health Insurance Portability and Accountability Act of 1996 (HIPAA), Privacy Rule (compliance deadline April 16, 2003), Security Rule (compliance deadline April 21, 2005).
U.S. Financial Services Modernization Act, also referred to as the Gramm-Leach-Bliley Act (GLBA), Title V – Privacy, Subtitle A, enacted November 12, 1999, effective November 13, 2000, Compliance by July 1, 2001. The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of Thrift Supervision (collectively, the Agencies) published final Guidelines establishing standards for safeguarding customer information that implement sections 501 and 505(b) of GLBA.

(1) Generally Accepted Privacy Principles	(2) Australia Privacy Act	(3) Canada PIPEDA	(4) E.U. Directive	(5) OECD Guidelines
Management		Accountability	Notification	Accountability
Notice	Openness	Identifying Purposes, Openness	Information to Be Given to the Data Subject	Purpose Specification, Openness
Choice and Consent	Use and Disclosure	Consent	Criteria for Making Data Processing Legitimate, Data Subject's Right to Object	Collection Limitation
Collection	Collection, Sensitive Information, Anonymity	Limiting Collection	Principles Relating to Data Quality, Exemptions and Restrictions	Collection (including consent) Limitation
Use, Retention, and Disposal	Identifiers, Use and Disclosure	Limiting Use, Disclosure, and Retention	Making Data Processing Legitimate, Special Categories of Processing, Principles Relating to Data Quality, Exemptions and Restrictions, The Data Subject's Right to Object	Use Limitation (including disclosure limitation)
Access	Access and Correction	Individual Access	The Data Subject's Right of Access to Data	Individual Participation
Disclosure to Third Parties	Use and Disclosure, Transborder Data Flows	Limiting Use, Disclosure, and Retention	Transfer of Personal Data to Third Countries	Use Limitation (including disclosure limitation)
Security for Privacy	Data Security	Safeguards	Confidentiality and Security of Processing	Security Safeguards
Quality	Data Quality	Accuracy	Principles Relating to Data Quality	Data Quality
Monitoring and Enforcement	Enforcement by the Office of the Privacy Commissioner	Challenging Compliance	Judicial Remedies, Liability and Sanctions, Codes of Conduct, Supervisory Authority and Working Party on the Protection of Individuals with Regard to the Processing of Personal Data	Individual Participation (including challenging compliance)

(1) Generally Accepted Privacy Principles	(6) U.S. FTC	(7) U.S. Safe Harbor	(8) U.S. HIPAA	(9) U.S. GLBA
Management			Administrative requirements
Notice	Notice	Notice	Notice	Privacy and Opt Out Notices, Exceptions
Choice and Consent	Choice	Choice	Consent, Uses and Disclosures	Privacy and Opt Out Notices
Collection		Data Integrity
Use, Retention, and Disposal		(Implied but not specified in the principles)	Uses and Disclosures	Limits on Disclosures
Access		Access	Access
Disclosure to Third Parties		Onward Transfer	Uses and Disclosures, Accounting of Disclosures	Limits on Disclosures
Security for Privacy	Security	Security	Security Rule	Security Guidelines mandated by section 501(b) of GLBA
Quality	Integrity	Data Integrity	Amendment
Monitoring and Enforcement	Enforcement	Enforcement	Compliance and Enforcement by the Department of Health and Human Services	Enforcement by financial services industry regulators, the FTC, and SEC

A A A

Print Page

Get a free version of Adobe Acrobat Reader