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Notes
1 The paper was a submission for the Morrison and Foerster Foundation's 2005 Barbara Wellbery Memorial Award.
2 Jay Cline is the data privacy officer of Carlson Companies, the parent corporation of businesses in the travel, hospitality, and marketing industries. Prior to joining Carlson, Jay was the lead CIA analyst on international trade law and negotiations.
3 These statistics are based on my own analysis.
4 Commission Staff Working Document, 20 October 2004: http://europa.eu.int/comm/justice_home/fsj/privacy/docs/adequacy/sec-2004-1323_en.pdf.
5 Few multinational companies, in fact, reach this ideal. Of the companies in the Forbes Global 100, US firms averaged 3.9 Safe Harbor principles in their privacy policies, while their EU counterparts averaged just 2.3, according to my own analysis: http://www.computerworld.com/developmenttopics/websitemgmt/story/0,10801,100946,00.html.
6 This viewpoint was summarized by Malcolm Crompton, former Privacy Commissioner of Australia, in a 2005 teleconference hosted by the Responsible Information Management (RIM) Council.
7 FTC settlements that have provoked widespread attention among US corporations include those with BJ's Wholesale Club (http://www.ftc.gov/opa/2005/06/bjswholesale.htm), Guess, Inc. (http://www.ftc.gov/opa/2003/06/guess.htm), and Eli Lilly (http://www.ftc. gov/opa/2002/01/elililly.htm), requiring comprehensive information security programs and audits for the next 20 years.
8 The first companies—General Electric, Phillips, and Daimler-Chrysler—to pursue EU approval for binding corporate rules, for example, have reportedly spent over a million dollars on the process.
9 Views to this end are regularly expressed by US-based multinationals giving presentations at privacy conferences such as those hosted by the International Association of Privacy Professionals and Privacy and American Business.
10 To view the framework: http://www.apec.org/apec/news_media/2004_media_releases/201104_apecminsendorseprivacyfrmwk.html.
11 To view the declaration: http://www.edsb.ch/e/doku/pressemitteilungen/2005/2005-09-16.htm.
12 Remarks to this effect were made by Bojana Bellamy, head of Accenture's privacy practice, and others at a Transatlantic Events conference on data protection in September 2005.