
Those who are affected in the first place are US companies who are used to collect and process personal data from their customers without any embarrassment. They will be excluded from the European market, if they do not follow European Data Protection rules. Until now the US goverment has decided to leave this matter to self regulation. However, US industry did not manage to come up with an appropriate codex. If industry does not comply until the end of the year, FTC promised that they will introduce a bill at congress which will comply with European data protection standards. On the other hand, the US did not even manage to adopt the Guidelines on the Protection of Privacy and Transborder Flow of Personal Data by OECD. The discrepancy in the US system is exposed by the fact that general laws for data protection and privacy were avoided in favour of specific laws for single areas or techniques. Other countries, in particular those in Eastern and Central Europe have, in spite of massive lobbying by D. Aaron, adopted laws on data protection and privacy since they do not want endanger their future participation in the EU. T. Schlickmann