In a just-published article for the American Bar Association Antitrust magazine entitled "So Close Yet So Far, The EU and US Visions of a New Privacy Framework." available here, Hogan Lovells Privacy partners Winston Maxwell (Paris) and Chris Wolf (Washington) compare and contrast the pending proposals on both sides of the Atlantic for improvements to the privacy frameworks.
[P]olicymakers around the world are re-examining the legal framework that regulates the collection, use, sharing, and storing of personal information––making more robust the protections afforded to such information, and increasing the legal obligations of business. The privacy frameworks recently proposed by the European Commission, the White House, and the FTC seek more protection of individuals, and are founded on the same underlying principles of fairness. However, despite common foundations, the privacy regimes from opposite sides of the Atlantic exhibit fundamental differences in approach and substance.
As things now stand there is a big gap to bridge between the two trans-Atlantic approaches. Both are, in many ways so close, yet very far apart in fundamental respects.