The Right to Privacy and the Conceptualisation of the Person in the Workplace: A Comparative Examination of EU, US and Australian Approaches - International Journal of Comparative Labour Law and Industrial Relations View The Right to Privacy and the Conceptualisation of the Person in the Workplace: A Comparative Examination of EU, US and Australian Approaches by - International Journal of Comparative Labour Law and Industrial Relations The Right to Privacy and the Conceptualisation of the Person in the Workplace: A Comparative Examination of EU, US and Australian Approaches 23 2
This paper examines the emerging debate on workplace privacy regulation in Australia by reference to related developments in the United States, the United Kingdom and selected European countries. Exploring the theoretical underpinnings and practical outcomes of the different approaches, the authors argue that Australia should reject the market-friendly model exemplified by the United States approach and adopt the more comprehensive and integrated approach found in Europe.
International Journal of Comparative Labour Law and Industrial Relations