Eu And The Americas Of Personal Data Protection System And The Enlightenment To China

The information technology industry in China started late but developed very quickly, even today, a relatively high informatization development level to promote personal data protection become the urgent need to solve social problems. Due to our current laws and regulations on the protection of personal data have been unable to meet the demand of social development, using the experience of Europe and the United States data protection to perfect our personal data protection system is very necessary. Shall be based on the information industry in our country and the market economy development level, degree of the public awareness of personal data protection, and other practical situation, with reference to the European and American experience, the establishment conforms to the national conditions and development needs of personal data protection system.In this paper, the first chapter will revolve around personal data and recognized the theme of the personal data and to concepts of personality right, the right of privacy, introduces European Union and determination of personal data and the relevant provisions of the standard, analyzing the rights of personal data protection, content, finally points out that should establish independent right of personal data.The second chapter introduces the European Union, the United States and Canada from the legislation system about personal data protection law system, and then focus on countries in the legal status of the subject, self-discipline, the understanding of the cross-border data transmission on issues such as comparative analysis, in the final analysis of international cooperation of the agreement and defects of the personal data protection system.Finally, in the third chapter will mainly introduce the present situation of the personal data protection and legislative situation in our country, combined with the reality of our country and Europe and the United States legislation practice of personal data, and put forward personal data protection system in our country should draw lessons from Europe and the United States the purpose of the personal data protection, the European Union model is adopted to establish the independence of the personal Data Protection Act, at the same time, based on the experience of the United States, according to the different environment or technical characteristics, design and relevant industry and technology is closely related to the substantive law or supplement, fully absorb the beneficial nutrient in the EU model and American model, forming clarity, clear aim, legislation technology advanced level, and clarify the rights and obligations of the personal data protection system.