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The Non-Americanization of European Regulatory Styles: Data Privacy Regulation in France, Germany, Italy, and Britain. CES Working Paper Series No. 174, 2010

Bignami, Francesca. (2010) The Non-Americanization of European Regulatory Styles: Data Privacy Regulation in France, Germany, Italy, and Britain. CES Working Paper Series No. 174, 2010. [Working Paper]

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    Abstract

    European countries have experienced massive structural transformation over the past twenty-five years with the privatization of state-owned industries, the liberalization of markets, and the rise of the European Union. According to one prominent line of analysis, these changes have led to the Americanization of European regulatory styles: previously informal and cooperative modes of regulation are becoming adversarial and litigation-driven, similar to the American system. This article explores the Americanization hypothesis with a structured comparison of data privacy regulation in four countries (France, Britain, Germany, and Italy) and a review of three other policy areas. It finds that European regulatory systems are converging, but not on American-style litigation, rather on an administrative model of deterrence-oriented regulatory enforcement and industry self-regulation. The explanation for this emerging regulatory strategy is to be found in government responses to market liberalization, as well as the pressure created by the governance process of the European Union.

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    Item Type: Working Paper
    Subjects for non-EU documents: Countries > Italy
    Countries > France
    Countries > Germany
    EU policies and themes > External relations > EU-US
    Countries > U.K.
    EU policies and themes > Policies & related activities > regulations/regulatory policies
    EU policies and themes > Policies & related activities > Third Pillar/JHA/PJC > general
    Subjects for EU documents: UNSPECIFIED
    EU Series and Periodicals: UNSPECIFIED
    EU Annual Reports: UNSPECIFIED
    Series: Series > Harvard University, Center for European Studies > CES Working Papers Series
    Depositing User: Phil Wilkin
    Official EU Document: No
    Language: English
    Date Deposited: 02 Aug 2010
    Page Range: p. 49
    Last Modified: 15 Feb 2011 18:33
    URI: http://aei.pitt.edu/id/eprint/14472

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