Prtivacy Laws v Freedom of Speech: US v Europe - a cultural gap on the right to be forgotten

The reverberations from this week's landmark European Court of Justice ruling on the right to be forgotten continue to be felt.

Legions of lawyers are still trying to work out what it will mean for the search engines, and for millions of EU citizens who may want to force them to remove links to their past online lives. And the cultural divide between Europe and the US appears wider than ever, with two very different views of how we should live our lives online.

On the one hand there is what you might call the web utopian view, held by the US internet giants and some in Europe who look to Silicon Valley for inspiration. This sees the ECJ ruling as unworkable, illiberal and just out of touch.

The Wikipedia founder Jimmy Wales, who divides his time between London and the US, explains to me why something like it could never happen across the Atlantic because of the constitutional guarantee of free speech: "This is not a debate the United States is even capable of entering into.

You'd have to repeal the First Amendment - and that's like a religious artefact - so that's never going to happen."

So a battle between two views of freedom - the US belief that free speech trumps everything, and the European view that individuals should have some control over what the world knows about them. But there is something else in play here, a growing unease about the power wielded by what are nearly always US web giants over our lives.

Note EU-Digest:  US Corporations, including Facebook, Yahoo and Google are comparing apples with Pears. The European Court of Justice decision is the right one because there is a distinct difference between Personal Privacy Laws and Freedom of Speech. Storing private information and selling that information to third parties without pernission is in no way linked to Freedom of Speech.

Congratulations to the European Court of Justice for a job well done. 

Read more: BBC News - US v Europe - a cultural gap on the right to be forgotten