A comparative study on surveillance and privacy regulations (the UAE vs. the USA and the EU)

Abstract

Surveillance is becoming the norm in today’s life, especially with the pandemic of COVID-19. Surveillance of public crowds and activity is a controversial issue that can contradict the privacy of individuals (Federal Decree-Law No. (5) of 2012). This paper presents a comparative study of surveillance and privacy regulations and law in the UAE compared to the USA and the EU. The objective of this comparison is to highlight the amendments that have been adopted to improve laws and regulations, the need for further improvement, and the strengths and weaknesses in each of these countries. A discussion of different acts adopted in these countries and comparing them can help security experts to cooperate with legislators in order to rectify shortcomings and improve the acts adopted in their respective countries. Furthermore, we think that such a comparison can help system developers to find an easier way to accommodate the differences in security measures that they have to tackle and incorporate when they are serving customers in these countries and especially in the UAE. A legal framework has been proposed in order to define the maturity level of regulations adopted by a government in regard to surveillance and privacy laws and acts.