The Indian Supreme Court is all set to pronounce its verdict on Thursday in ‘Right to Privacy case’. A nine-judge Constitution bench, dealing with the contentious issue whether right to privacy was a fundamental right, had rejected plea of a Gujarat government lawyer that misuse of personal information could be dealt with on a "case-to-case basis" and said an all-embracing guideline was needed keeping in mind the size of the population.
In such a scenario, when our country is debating on the issue, let’s have a look at privacy policies around the globe:
The United States:
In the United States, data privacy isn’t highly legislated on a federal level. A lot like with many issues, the federal government leaves a lot of the details up to each state. Some federal laws that touch on data privacy include the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which deals with health-related information, and the Children’s Online Privacy Protection Rule (COPPA), which applies to websites that collect data from children under the age of 13.
In the UK, the mission of the Information Commissioner’s Office is to “uphold information rights in the public interest.”The Data Protection Act requires fair processing of personal data, which means that you must be transparent about why you’re collecting personal data and how you’re going to use it.
The European Union Data Protection Directive of 1998 states that anyone processing personal data needs must do so in a fair manner. In order for the data collection to be considered lawful, data can only be collected for specified, explicit and legitimate purposes, and users must give explicit consent after being informed that data collection and processing is taking place.
Canada’s Personal Information Protection and Electronic Data Act (PIPEDA) governs how you can collect, store, and use information about users online in the course of commercial activity. According to the act, you must make information regarding your privacy policies publicly available to customers.
In Japan, The Personal Information Protection Act protects the rights of individuals regarding their personal data. The act states that you must describe as specifically as possible the purpose of the personal data you’re collecting. Also, in order to share the personal data with any third party (such as an email newsletter service) one needs to obtain prior consent.