Affiliations: [a] Department of Society and Globalisation, University of
Roskilde, Hus 25.2, DK-4000 Roskilde | [b] Division of Business and Organisation, University of
Stirling, Stirling, FK9 4LA
Correspondence:
[*]
Correspondence author: Dr. Karl Löfgren, Department of
Society and Globalisation, University of Roskilde, Hus 25.2, DK-4000 Roskilde.
Tel.: +45 4674 2859; E-mail: [email protected]
Abstract: This article examines policy activity surrounding the implementation
of privacy regulations in three European countries, Denmark, Sweden and the UK,
following the ratification of the 1995 European Union Directive on Data
Protection. It highlights the convergence and divergence of policy embedded in
the policy transfer process and stresses not only the complexity of policy
transfer, but also the degree to which policy innovation is shaped by existing
institutional settings and the processes associated with policy implementation.
The article uses Dolowitz and Marsh's 'Policy Transfer Model' as an analytical
tool to unpack the regulatory environment surrounding the governance of
privacy. This illuminates the main features of the policy process in each of
the three case study countries and also the tendency to focus on policy
formation at the expense of policy implementation. In the case of the 1995
European Union Directive on Data Protection the three cases examined here
demonstrate that multiple regulatory regimes and policy divergence are embedded
in the harmonisation (or convergence) process, and that different countries
approach the regulation of privacy and data protection in quite different
ways.
Keywords: Data protection, policy transfer process model, European union directive on data protection (95/46/EC), privacy Regulation
