Abstract
This paper presents the findings of a comparative study of laws and policies employed to protect personal data processed in the context of e-government in three countries (the United States, Germany, and China) with rather different approaches. Drawing on governance theory, the paper seeks to document the mechanisms utilized and to understand the factors that shape the governance modes adopted. The cases reveal that national government regulations have not kept pace with technological change and with the current information practices of the public sector. Nonetheless, traditional government regulation remains the major governance mode for the issue under discussion. Self-regulation and code-based regulation serve supplementary roles to traditional government regulation. National context is found to impact the form and level of data protection and the choice of governance modes.
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