A Comparative Study Of Privacy Laws Of Online Users On Social Media Of The Us And The EU:With Suggestions On China's Privacy Protection

Against the backdrop of worldwide constant data breach incidents on social platforms,this thesis offers suggestions of strengthening industry self-regulation and reform in legislative and law enforcement branches on online privacy protection in China by comparing the laws and regulations concerning online privacy right and other protection approach taken by the United States and the European Union.The US mainly relies on industry self-regulation,and a series of sectoral laws and regulations have played a supplementary role.Non-binding industry self-regulation has less impact on the development of data-driven enterprises,but it cannot protect users' data privacy effectively.Sectoral laws and regulations have protected special groups of people such as underage youth or restricted government's unlawful access to citizen's information,but the US still lacks a comprehensive law concerning online privacy right.While the EU inclines to adopt stringent comprehensive laws and regulations to regulate marketplace.The General Data Protection Regulation implemented in 2018 has been considered as the most stringent privacy law in history.Heavy penalties would be imposed upon the companies which violate the privacy protection requirements.Such approach guarantees the security of users' data.Online users' data leakage by many Chinese Internet companies have revealed that privacy protection of China's Internet users is inadequate.General Provisions of the Civil Law of the People's Republic of China merely stipulates that a natural person enjoys privacy right,and its personal information shall be protected.Cybersecurity Law of the People's Republic of China has detailed regulations of collection and usage of users' personal information conducted by the data collectors and penalties.However,China still lacks a comprehensive privacy law and a data protection agency to supervise the marketplace.After learning experience from the US and the EU,China could protect users' online privacy right by strengthening industry self-regulation and reform in legislative and law enforcement branches.A data protection agency under the State Council should be established and a stringent privacy law should be enacted to restrict the illegal collection,usage and leak of users' personal data by the tech giants to meet the end of users' dataprotection.Besides,under the circumstance of legal supervision vacancy for the time being,industry self-regulation could be taken as a supplementary approach,and China's Internet industry could timely formulate or adjust privacy protection guideline based on the status quo,so as to balance privacy protection and efficiency.