One of the basic differences is in the definition of "accountability." In both the U.S. and the EU a data holder is supposed to be accountable for abiding by the principles of consumer rights. In the EU, governmental authorities have big sticks they can use to punish data holders who do not do their part -- up to 2% of a company's annual revenue under the proposed updates.
In the United States there is far less of a governmental role. The Obama blueprint proposes to strengthen the role of the Federal Trade Commission (FTC) in enforcement, but historically the FTC has been more of a kitten than a tiger when it comes to enforcement. Most of the time the FTC gets a company to agree to not be bad again and to pay a fine that represents a small percentage of the extra money the company made from the violation. The Obama blueprint wants "a sustained commitment of all stakeholders to address consumer data privacy issues as they arise from advances in technologies and business models." "Commitment" is all well and good, but a few big sticks might meaningfully increase the level of commitment.
Having said all that, some movement toward the Obama blueprint would be nice. I can understand why there was not much movement in an election year but, with President Obama re-elected, it is time to move. Some progress here might avert the worst of the trade war with the EU predicted by one U.S. official. It might also be good for you and me, whose data is cached in places we have no idea even exist.
Disclaimer: Harvard, I assume, obeys EU rules when in the EU but has expressed no opinion on either the Obama blueprint or the updated EU rules. So the above is my desire for a tiny bit of privacy.
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