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강구철(Kang Koo-Chul) 국민대학교 법학연구소 2005 법학논총 Vol.17 No.-
The data protection systems are distinguished into a rights-dominated approach and a market-dominated approach. EU has adopted a rights-dominated approach, for example Germany, and The U. S. has adopted a market-dominated approach. Germany has ever had a comprehensive data protection law which covers the personal data processing both in the public and private sector. The U. S. has no comprehensive data protection law but many special laws in the private sector. Japan has many special laws in the private sector, but in 2003, established Data Protection Act which covers the personal data processing in the private sector. Many countries has established a unified data protection law in private sector, and the others, including The U. S., try to do recently. These are suggesting the trend of the world to us who has no comprehensive data protection law.