“To legislate or not to legislate”: a comparative exploratory study of privacy/personalisation factors affecting French, UK and US Web sites

The trade off between customer privacy and Web site personalisation is currently moving to the forefront of academic and practical debate in marketing. The new Internet applications allow marketers to develop detailed customer databases where personal information is connected with buying patterns, providing a detailed behavioural profile. The collection and use of the data is regulated differently in the European Union and the USA. While Europe considers it important to implement formal legislation for the protection of customers’ privacy rights, the US authorities consider privacy policy to be determined through voluntary regulation by industry. Considering these different approaches, the present study explores and compares the privacy/personalisation dimensions of French, British and US Web sites.