The Three Paths to Privacy

Abstract

In the field of data governance, a comparative analysis of the policies pursued by the European Union, the United States, and the People’s Republic of China can be represented through three historical metaphors with clearly differentiated regulatory logics: the Camino de Santiago, Route 66, and the Silk Road. The Camino de Santiago, characterized as a supranational network of protection, hospitality, and shared rules, reflects the approach of the European Union, where privacy is conceived as a fundamental right. In this sense, the medieval pilgrim and the digital citizen share a framework designed to protect them during their journey, ensuring that mobility (whether physical or digital) remains a central element of European cohesion and identity. By contrast, the American Route 66 symbolized a conception of mobility associated with individual freedom and entrepreneurial spirit. Along Route 66, rules were minimal and the driver assumed responsibility for managing risks and opportunities. This logic is consistent with the U.S. regulatory tradition, characterized by limited state intervention and a strong preference for self-regulation and the free market. The Silk Road, as a historical route of controlled exchange and a tool for projecting imperial strategic power, helps explain the Chinese model, which is based on digital sovereignty, the centrality of the state, and the primacy of national security. Chinese legislation establishes a regime that combines formal protection of the individual with a pronounced authoritarian dimension. Taken together, these three models reveal a fragmented global landscape in which rights-based, liberal–market-oriented, and sovereignist approaches coexist, generating structural tensions in data governance and in its regulatory viability