| Netz DG [June 2017] | GDPR [May 2018] | CCPA [June 2018] |
| • Providers must deal with illegal content or face fines of up to 5 million euros | • providers must clearly disclose * any data collection * the purpose for collecting data * how long data is kept * if it is shared with 3rd party |
• users must know what personal data is collected |
| • The Telemedia Act provides for publication of a user's master data | •users have the right to request data | • users must know whether data is sold to 3rd party |
•users have the right to erase data under certain circumstances |
• no selling of personal data | |
| •must employ a data protection officer | • users can request to delete persona information | |
| •data breaches must be reported within 72 hours | • no discrimination against single persons | |
| fines up to 20 million euros | • fines up to $7500 for each infraction | |
| Criticism: | Criticism: | |
| • dampens free expression and may be an infringemet of human rights | very limited jurisdiction | |
| • puts providers in posisiton of judging content, not the state | ||
| • may be unconstitutional with respect to the German constitution | ||
| Effectiveness: | Effectiveness: | |
| Since 2017 90% of punishable content on YouTube has been taken down, 39% of punishapble content has been taken down on Facebook, 1% of punishable content has been taken down | Facebook sued for non-compliance with opt-in for data collection | |
| British Airways fined 183 million euros for poor security that allowed data attack | ||