Friday, October 22, 2010

Privacy: the Transatlantic Divide

Despite what the likes of Mark Zuckerberg may say, there are still some people who strongly care about privacy.  This seems to be more so the further east you go from Silicon Valley. And even in the Valley, an increasing number of people are becoming aware of this, even though they may not understand or appreciated the alternate viewpoints.

Whenever I am asked for an opinion on the European "obsession" with privacy or for an explanation on why the Germans seem so incredibly hung-up on privacy, my standard answer goes about as follows:

Yes, there are indeed differences in the approach and attitude to privacy in particular between the US and non Anglo-Saxon continental Europe, but in substance the differences may be smaller than the commonality. And yet we humans seem to be particularly good a picking out small (cultural) differences and get disproportionately stressed-out over over them. In robotics when a humanoid model is close, but just doesn't feel quite right,  this effect is called the uncanny valley. It is also very hard to really understand any alternate viewpoint which derives from a different experience that is not ones own.

For somebody with a US perspective, maybe the following analogy with freedom of speech is worth considering. Practically all major democracies have a strong constitutional commitment to freedom of speech (often called freedom of expression outside the US). And yet when it comes to trading off freedom of speech vs. other fundamental rights, the US typically strikes the balance strongly in favor of freedom of speech, while Europeans typically favor the kinds of human rights which protect the individual from harm. Americans overall feel very strongly about freedom of speech and are willing to make sacrifices in other areas to support it.

Since the current debate about privacy rights on the Internet is also much about the conflict between freedom of expression and the protection of the individual, this difference in tradition and priorities might also explain a good part of the difference in approach and attitude on both sides of the Atlantic. While in Europe privacy and data protection is considered a human right per-se, the US rather sees it as a consumer protection issue, mostly concerned with material damages.

Another explanation for the difference in attitude towards data protection in particular is that many Europeans have a recent memory of where the abuse of information can lead. The use and abuse of information played an important role for both fascist and socialist totalitarian regimes through much of the 20th century in Europe.  As Vaclav Havel describes in the "The Power of the Powerless", the essential source of power for a post-totalitarian system rests in its ability to control information in order to create a collective distortion of reality ("living a lie").

And finally, anybody who wants to better understand the fears of excessive data collection and abuse of personal information, should watch the excellent German film and 2007 winner of the best foreign language academy award -  "The Lives of Others".