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The Regulation of Commercial Profiling – A Comparative Analysis

Abstract

The authors, all data protection experts, discuss the status of the relevant data protection regulatory framework on profiling in the business sector in sev- eral countries worldwide, from the constitutional lev- el to some individual regulation including the gener- al attitude towards the topic. The EU perspective is presented on the basis of the present directives as well as the General Data Protection Regulation. The United Kingdom, Germany and France, as three of the largest EU Member States with partly highly dif- fering regulatory approaches represent Member State law. Australia, Brazil and the US regulation ex- emplify the different integration of data protection standards and different models of approaching pro- filing in the globalised IT world.*

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