http://www.azcentral.com/arizonarepublic/news/articles/0319idtheft0319.html

Theft of ID is tougher in Europe

Shelley Emling Cox News Service Mar. 19, 2006 12:00 AM

LONDON - To Europe, America looks a lot like one big Wild West still in need of some taming, at least when it comes to privacy laws.

Privacy experts say that stricter controls on personal data and credit cards make it much harder for criminals in Europe to steal someone's identity or to use someone else's accounts to make financial transactions.

"The United States today experiences much higher levels of identity theft, spam and government profiling than Europe because we have failed to establish necessary legal safeguards," said Marc Rotenberg, executive director of the Electronic Privacy Information Center (EPIC), a Washington, D.C.-based advocacy group.

"Simply stated, Europe has done a better job safeguarding privacy, while the failure of the United States to adopt comparable protections has imposed real economic costs for consumers and businesses," he said.

Simon Davies, director of Privacy International, a watchdog group in London, said a culture of privacy protection has existed in Europe for decades.

The European Convention on Human Rights, drafted in the 1950s, specifically guarantees citizens the right of privacy.

And many looming privacy problems were dealt with in Europe during preparations for the 1992 integration of the European Union.

As a result, what's known as the EU Data Protection Directive, a comprehensive framework for privacy protection, was established before many of the world's major privacy problems emerged.

"Controllers of personal data in Europe are required to provide rigorous protections," Davies said, adding that "there are limited privacy safeguards in the United States."

Davies estimates that ID theft is four times more prevalent in the United States than in Britain, and that ID theft is even less common in other parts of Europe.

One major difference is that many European countries don't use anything akin to a Social Security number as a ubiquitous identifier.

"People in many European countries are known by an array of numbers," Davies said.

"But in the United States the Social Security number links all the activities of an individual and is key to identity theft.

"We believe that use of the number has spun entirely out of control," he said.

Also limiting the potential fraud damage in Europe is that consumers there are less likely to use credit cards when making a purchase, especially over the Internet, than they are to use cash or prepaid debit cards.

"Europeans are a little more conservative when it comes to shopping habits than Americans," said Tom Buk-Swienty, a professor in Denmark.

"Europeans are somewhat afraid of using their credit cards to buy items over the Internet.

"For example, it can be very difficult for bookstores to sell online," he said. "Many people just won't buy that way."

As another safeguard, many European countries prohibit companies from sharing or selling personal information or records unless they first get consent.

Robert Ellis Smith, a privacy expert and publisher of the Privacy Journal in Providence, R.I., said that in general, Europeans tend to take "an omnibus" approach to regulating all records systems, large and small, even if many are not crucial to citizens' rights.

"This type of system is a simple system to understand, but tends to generate a lot of paperwork compliance," he said.

Smith said the United States tends to take a more "sectoral" approach, enacting legislation to regulate systems where the most sensitive information is kept and where complaints have arisen.

"This is more cost-effective, but it can also leave some huge gaps, such as no protection of employment records," he said.

He also pointed out that the United States is the only developed country with privacy protections but no privacy officer at the federal level.

Despite its restrictions, many parts of Europe have seen a rise in ID theft over the past few years.