Information privacy and marketing: What the US should (and shouldn't) learn from Europe

The U.S. and Europe exhibit very different approaches to information privac y-a condition of limited access to identifiable information about individua ls-from both regulatory and managerial perspectives. Grounded in different cultural values and assumptions about the meaning of privacy (a "human righ ts" issue in Europe versus a contractual issue in the U.S.), these differen ces have led to regulatory and managerial conflicts. In this article, the d ifferences between the two approaches are explored. U.S. corporations would be well served to embrace some of the premises of the European perspective . However, the U.S. would be poorly served by the creation of a federal reg ulatory structure such as some commonly found in Europe.