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A comparative study of online privacy regulations in the U.S. and China

Author

Listed:
  • Wu, Yanfang
  • Lau, Tuenyu
  • Atkin, David J.
  • Lin, Carolyn A.

Abstract

Online privacy seeks to protect the identity of individuals who use the internet to collect information or express opinions. However, given the proliferating vehicles through which one's identity can be ascertained, the question remains as to what policies can most effectively protect personal identity. This paper explores the similarities and differences with online privacy regulation in the United States and China. The scope of privacy measures examined here ranges from government to personal levels, from communication and finance to personal records, for adults and children. As might be expected in a democracy, American legislative initiatives are more comprehensive and far-reaching than those of their Chinese counterparts. In China, there was until recently no specific right of privacy specified in dedicated legislation, with privacy having been instead protected under the right of reputation in the Civil law. Policy implications stemming from these competing models are evaluated. Study findings underscore the notion that privacy should be a universally established individual right, and that both countries are moving--at least in rhetorical terms--to strengthen it as such.

Suggested Citation

  • Wu, Yanfang & Lau, Tuenyu & Atkin, David J. & Lin, Carolyn A., 2011. "A comparative study of online privacy regulations in the U.S. and China," Telecommunications Policy, Elsevier, vol. 35(7), pages 603-616, August.
    • Handle: RePEc:eee:telpol:v:35:y:2011:i:7:p:603-616
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    Citations

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    Cited by:

    1. Zhang, Huiping & Tang, Zhiwei & Jayakar, Krishna, 2018. "A socio-technical analysis of China's cybersecurity policy: Towards delivering trusted e-government services," Telecommunications Policy, Elsevier, vol. 42(5), pages 409-420.
    2. Wei Han, 2020. "The analysis on Chinese e-commerce tax losses based on the perspective of information asymmetry," Electronic Commerce Research, Springer, vol. 20(3), pages 651-677, September.
    3. Guo Li & Na Li, 2019. "Customs classification for cross-border e-commerce based on text-image adaptive convolutional neural network," Electronic Commerce Research, Springer, vol. 19(4), pages 779-800, December.
    4. Yini Wang & Mark Balnaves & Judith Sandner, 2020. "Shameful Secrets and Self-Presentation: Negotiating Privacy Practices Among Youth and Rural Women in China," SAGE Open, , vol. 10(1), pages 21582440209, January.
    5. Xian Xu & Peter Zweifel, 2020. "A framework for the evaluation of InsurTech," Risk Management and Insurance Review, American Risk and Insurance Association, vol. 23(4), pages 305-329, December.
    6. Huiying Hu & Jing Wang & Ming Zhu, 2017. "The official websites of blood centers in China: A nationwide cross-sectional study," PLOS ONE, Public Library of Science, vol. 12(8), pages 1-13, August.
    7. David Karpa & Torben Klarl & Michael Rochlitz, 2021. "Artificial Intelligence, Surveillance, and Big Data," Bremen Papers on Economics & Innovation 2108, University of Bremen, Faculty of Business Studies and Economics.
    8. Xingyuan Wang & Yun Liu & Hongchen Liu, 2020. "Examining Users’ Adoption of Precision Medicine: The Moderating Role of Medical Technical Knowledge," IJERPH, MDPI, vol. 17(3), pages 1-16, February.

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