欧美个人信息保护政策的分歧与妥协以及对我国的启示

Divergence and Compromise of Personal Data Protection Policy Between EU and USA

作为两个世界上最有影响力的个人信息保护政策模式,欧盟和美国不遗余力地传播符合他们价值和利益的政策体系。在分析欧美的政策分歧和妥协的基础上,提出制定并改善我国的个人信息保护政策的建议,在我国个人信息保护立法过程中,建立基本价值立场、完整机构,以及跨境数据的保护政策。

As two of the world＇s most influential personal information protection policy models, the Euro-pean Union and the United States spare no efforts to spread their policies system in conform of their value and interest respectively. Based on the comparison between the European and American＇s policies as well as the profound reasons behind suggestions are pro-posed for China to improve its personal information protection policies; it is suggested that China should push forward its national personal information protection legislation by which it can establish its basic value position and the complete institution as well as the cross border data flow protection policy.