PRIVACYTowards A Useable Conception.

Privacy - An Essential Component Of Being Human• Universally recognized as being essential for Freedom, Human

Interactions, Democracy, the very fabric of Society – allows one to maintain varied sorts of relationships.

"the most comprehensive of rights and the right most valued by civilized men”

-United States Supreme Court Justice Louis Brandeis

“The right to privacy is an integral part of our humanity; one has a public persona, exposed and active, and a private persona, guarded and preserved.

The heart of our liberty is choosing which parts of our lives shall become public and which parts we shall hold close.”

-Minnesota Supreme Court Chief Justice Kathleen Blatz

"The right to be let alone is indeed the beginning of all freedom.”

-United States Supreme Court Justice William O. Douglas

Universally recognized as a human right

• United States Constitution 14th amendment, recognized by the Supreme Court as protecting Privacy.

• “Everyone has the right to privacy, which includes the right not to have their person or home searched; their property searched; their possessions seized; or the privacy of their communications infringed.” – South African Constitution

• “Everyone has the right to be secure against unreasonable search or seizure.” – Canadian Charter Of Rights And Freedoms.

• “Everyone has the right to respect for his private and family life, his home and his correspondence.” - Article 8 of the European Convention on Human Rights, Signatories include 47 European States.

• “No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honor and reputation. Everyone has the right to the protection of the law against such interference or attacks.” – Universal Declaration Of Human Rights, Ratified By the United Nations General Assembly with no State voting against.

• “Everyone should observe an appropriate reserve concerning persons' private lives. Those in charge of communications should maintain a fair balance between the requirements of the common good and respect for individual rights. Interference by the media in the private lives of persons engaged in political or public activity is to be condemned to the extent that it infringes upon their privacy and freedom.” - Catechism of the Catholic Church

Conceptions of Privacy infected with copious amounts of ambiguity.• There seems to be universal agreement on the sanctity of privacy and

the need for its protection, but there exists widespread ambiguity in conceptualizing privacy.

• Ambiguity in the conception and articulation of privacy concerns, i.e. what is at stake when privacy is lost, has lead to a disastrous erosion of privacy. Where on the one hand one sees an alarmed public, while on the other not much is being done. Even with widespread agreement on privacy’s importance for democracy, freedom etc., ambiguity in its conception leads to inaction.

“Privacy seems to encompass everything, and therefore ”- Law Professor Daniel Solove

“Privacy is a value so complex, so entangled in competing and contradictory dimensions, so engorged with various and distinct meanings, that I sometimes

despair whether it can be usefully addressed at all.”

- Philosopher Robert C. Post

“Perhaps the most striking thing about the right to privacy is that nobody seems to have any very clear idea what it is.”

- Philosopher Judith Jarvis Thomson

In England, discontent over defining privacy led the Younger Committee on Privacy to recommend in 1972 against recognizing a right to privacy as was

proposed in legislation at that time. The major difficulty in enacting a statutory protection of privacy, the committee report declared, is the “lack of any clear

and generally agreed definition of what privacy itself is.” Courts would struggle in dealing with “so ill-defined and unstable a concept”.

- Professor Of Law Daniel Solove states:

• Most conceptions of privacy suffer from being too broad i.e. too vague to grasp its essence and be useful, or too narrow where many aspects of what we consider to be a part of the essence of privacy is not encompassed.

Need for Conceptualizing Privacy, Usable Privacy

• Various Laws, Privacy policies purport to protect one’s privacy. The 911 commission in its report for example recommended that the varied government agencies share information, but in a manner that “Safeguards the privacy of individuals about whom information is shared”, but what does “Safeguards the privacy” mean in this case?

• A firm enough conception of privacy which is not too ambiguous, is required for there to be an effective respect and safeguarding of the privacy of individuals.

• Privacy is definitely not merely a positive right, it is also a negative right, For the concept of privacy does not exist in the vacuum of one persons mind. It comes to being in social interactions, somewhat like language. No one person invents language or new words in a language, it comes to being in social interactions and it lives in the space of social interactions. Like language, privacy consists of inter-personal rules, norms that one needs to follow in interaction between persons. The negative right aspect of privacy requires that individuals refrain from engaging in certain activities. Without a firm enough conception of privacy, the state cannot effectively enforce these negative rights.

When people claim that privacy should be protected, it is unclear precisely what they mean. This lack of clarity creates a difficulty when making policy or resolving a case

because lawmakers and judges cannot easily articulate the privacy harm. • -Daniel Solove, Professor of Law at George Washington University

• Just like grammarians who study language, its complex rules and conventions; this module is a survey of the various conceptions of privacy, their merits and shortfalls.

• The essential problem here is: how can one conceive of privacy where it is not too vague, rendering it ineffective in practice and not too narrow to where it does not encompass major aspects of what me mean by privacy.

• Various websites, products provide us with long privacy policies, ask us to choose levels of privacy etc. By striving for a conception of privacy which is not too ambiguous, a notion of Useable privacy can be achieved. Useable privacy aims to address the problem of ambiguity leading to inactivity, confusion and in general the erosion of core aspects of privacy due to disagreement on small details. As Daniel Solove states “A few things might be left out but the aim is to establish a conception that encompasses most things that are commonly viewed under the rubric of privacy”

• Privacy policies will be more clearer, will more effectively get across what a particular business intends to do about protecting privacy. Young users using Facebook etc. may be given a default privacy setting that is more appropriate and effective, and they will be able to more effectively apply custom privacy settings.

Various Conceptions Of Privacy – A Survey.

• The various conceptions of privacy can be derived form the following core ideas, the following slides will explore each of these conceptions in detail including their merits and shortcomings :1. The right to be let alone.

2. Limited access to the self-The ability to shield oneself from unwanted access by others.

3. Secrecy – The concealment of certain matters from others.

4. Control over personal information.

5. Personhood – The protection of one’s personalities, individuality and dignity.

6. Intimacy – Control over, or limited access to one’s intimate relationships.

The right to be let alone.• In 1890, Samuel Warren and Louis Brandeis published

their seminal work “The Right To Privacy”, This article in the Harvard Law Review is considered as the earliest and most influential work shaping privacy related common law in the United States. It spawned off at least four primary privacy related common law torts.

• The article was a response to a growing trend in sensationalism at that time. With the availability of cheap Kodak cameras came a thriving tabloid industry. Warren and Brandeis describe the situation: “The press is overstepping in each direction the obvious bounds of propriety and decency” “ Gossip is no longer the resource of the idle and of the vicious, but has become a trade”

• Warren and Brandeis define privacy as the “right to be let alone”, they claim that while laws against defamation prevent injury to reputations and such, the right to privacy was “the right of determining ordinarily, to what extent one’s thoughts, sentiments and emotions shall be communicated to others”

• The United States Supreme court adopted Warren and Barndeis’s view of privacy in Katz v. United States (1967), where it extended the Forth amendment’s unreasonable search and seizure clause protection to all areas where there is a “reasonable expectation of privacy” i.e. a warrant is required for legal intrusion of spaces where one has a “reasonable expectation of privacy” Overturning a long standing court ruling Olmstead v. United States (1928) which allowed for warrantless wiretapping.

• In his majority opinion in Katz v. United States Supreme Court Justice Abe Fortas observed “to live one’s life as one chooses, free from assault, intrusion or invasion, except as they can be justified by the clear needs of community living under a government of law”

• Justice William O. Douglas agreed by directly quoting Brandeis “The right of privacy was called by Mr. Justice Brandeis “the right to be let alone”. That right includes the privilege of an individual to plan his own affairs, for outside areas of “plainly harmful conduct, every American is left to shape his own life as he thinks best, do what he pleases, go where he pleases.””

• Understanding privacy as a “right to be let alone” in one sense seems like a tautology, for the natural question of “on what matters should one be let alone” comes up.

• This new Question seems to be a re-formulation of the essential question of what Privacy is. As Law professor Anita Allen claims – punching someone would violate “right to be let alone” but punching is not considered a violation of privacy while a peeping in a bedroom is considered a violation of privacy.

• The real ethical work seems to be done by other underlying factors, “right to be let alone” is one of the privileges that one should enjoy in private mattes, but it is not a conception of what one means by “private matters”

• Even as a legal right, where “right to be let alone” refers to non-interference by the state, as legal scholar Ruth Gavison argues, Most privacy claims are not for non-interference by the state, but rather for interference by the state in resolving privacy infractions by other individuals.

Limited access to the self. – The ability to shield oneself from unwanted access by others.• The conception of privacy as Limited access to the self can be

summarized as the Right of every man to keep his affairs to himself, and to decide for himself to what extent they shall be the subject of public observation and discussion.

• Limited access to the self is not merely solitude. Solitude is a form of seclusion, of withdrawal from other individuals, of being alone. Limited access includes Solitude but goes further, embracing freedom from press surveillance, interference from the government etc.

“nothing is better worthy of legal protection than private life, or, in other words, the right of every man to keep his affairs to himself, and to decide for himself to what extent they shall be the subject of public

observation and discussion”

-E.L. Godkin

Privacy is the exclusive access of a person to a realm of his own. The right to privacy entitles one to exclude others from watching, utilizing,

invading his private realm.

-Ernest Van Den Haag

• “Limited access to the self” conceptions of privacy are essentially more sophisticated ways of conceiving privacy stemming from the original notion of “right to be let alone”. Where now the idea of the will segregating aspects of one’s life is more clearly ascribed to the notion of privacy.

• Certainly not all access to the self violates privacy, only access to certain areas of the self involve privacy concerns, as Daniel Solove, Professor of Law claims “The theory provides no understanding as to the degree of access necessary to constitute a privacy violation, in the continuum between absolutely no access to the self and total access, the important question is where the lines should be drawn – that is , what degree of access should we recognize as reasonable?”

• Like the “Right to be let alone”, Limited access to the self formulations of privacy are ambiguous and broad. Where the line Is between Private Vs. Non-Private matters is not clear. Certainly photographing a person in public does not seem to violate privacy, but photographing persons from certain angles even in public areas violates privacy. In defining this distinction lies the crux of what we mean by privacy, which this conception fails to address.

• To address this ambiguity, Legal Theorist explains what constitutes limited access. Gavison defines access by restricting privacy matters to withdrawal and concealment.

• However such restriction leads to her conception of privacy being too narrow, for it ignores privacy concerns rising from The Government’s interactions in private decisions regarding ones body, health etc.

Secrecy – the concealment of certain matters from others.• Secrecy is perhaps the most prevalent understanding of

the term Privacy. In this category of views, a person’s privacy is violated when certain previously concealed information is released publically.

• Secrecy specifically deals with information, i.e by its nature information may exist external to the self. In this sense this conception of privacy is different from the conception of “being left alone”.

The word ‘privacy’ seems to embrace at least two distinct interests. One is the interest in being left alone—the interest that is invaded by the unwanted

telephone solicitation, the noisy sound truck, the music in elevators, being jostled in the street, or even an obscene theater billboard or shouted obscenity. The other

privacy interest, concealment of information, is invaded whenever private information is obtained against the wishes of the person to whom the information

pertains.

- Judge Richard Posner

• The conception of privacy as Secrecy may be seen as a subset of “Limited Access To The Self” where access is restricted specifically to private information about oneself. In doing this, it avoids the problems related to other conceptions where it can be claimed that punching a person is a violation of privacy.

• As Poser further claims “People want to manipulate the world around them by selective disclosure of facts about themselves”

• Secrecy has been interpreted by the courts rather narrowly. No matter the extent of disclosure, with any public disclosure ones looses his right to privacy in that matter. i.e. there can be no “reasonable expectation of privacy” when certain information is exposed to the public, no matter how unlikely its discovery. The supreme court has held that in Garbage, when placed in a manner where it is readily accessible by children, animals etc there can be no expectation of Secrecy. Likewise the court has held that Surveillance of a person’s property from navigable airspace does not violate one's privacy.

• This flavor of conception of privacy is too narrow, Privacy does not exist in strict absolute terms as conceptualized by Secrecy. In interactions with others, one would validly like to set boundaries for Secrecy at various levels. In Criticizing a boss to a co-worker one rightly expects a level of secrecy. One expects in many situations a selective disclosure, where privacy is expected from a group to which information has been divulged. i.e. privacy is expected when sharing information with a select group of trusted people.

We become what we are not only by establishing boundaries around ourselves but also by periodic opening of these

boundaries to nourishment, to learning, and to intimacy. But the opening of a boundary of the self may require a boundary farther

out, a boundary around the group to which we are opening ourselves.

• -Sociologist Arnold Simmel

• Privacy is much more than just avoiding disclosure, it has an aspect of control to it. Privacy also involves ones ability to control how their private information is used.

• Very many things we do everyday, in public i.e. the books we buy, products one purchases at the supermarket etc. are considered to be private matters. This is not because these activities are carried out in secrecy but because as Stanley Benn States “are matters that it be inappropriate for other to try to find out, much less report on, without consent.

• Using the notion of Secrecy, especially as interpreted by the courts leads to a rather narrow conception of privacy. Which ignores privacy expected in group interactions.

Control Over Personal Information• Control over personal information is a leading theory of

privacy. Alan Westin one of its foremost proponents describes privacy as “Privacy is the claim of individuals, groups or institutions, to determine for themselves when how and to what extent information about them is communicated to others”

“Privacy is not simply an absence of information about us in the minds of others, rather it is the control we have over information

about ourselves”

-Charles Fried

“An individual’s claim to control the terms under which personal information – information identifiable to the individual – is

acquired, disclosed and used.”

- President Bill Clinton’s Information Infrastructure Task force.

• The “control over personal information” conception of privacy is a subset of the “limited access” conception. It focuses purely on information. By doing so it ignores privacy’s contribution to the freedom of making individual choice, i.e. choice of making decisions about reproduction, family etc.

• It is also in some sense vague like the other conceptions whereby it fails to shed light on what kinds of information are in the realm of privacy. Surely Control over personal information conceptions cannot include “all control over all information about oneself, one’s group, one’s institutions etc.

• In an attempt to limit the scope of “personal information” Various theorists have come up with modifications to the conception of “Control Over Personal Information”.

• Legal scholar Richard Parker defines personal information as “Control over who can see us, hear us, touch us, and taste us. This surely is too broad a conception. Surely ones does not feel that his privacy is violated when he is pat on the back even without prior approval.

• Others limit personal information to what strictly relates to the individual. Richard Murphy an economics scholar defines personal information as “any data about an individual that is identifiable to that individual”. However this purported “limit” is also too broad. There is a significant amount of identifiable data that is not considered private by an individual. Like the fact that one is a student, a teacher, a male, a professor etc.

• In most conceptions of “Control Over Personal Information” Information relating to an individual is seen as property. In some sense it is seen as the “intellectual property” of a person who generates personal information as he goes about his day to day activities.

• This generated information is “his”, just like the chair he owns is “his”, and he therefore can control the dissemination of this private information.

• The problem with viewing personal information as property is that information can be easily transmitted and can easily spread with interactions between humans. This is why as Patent Attorney Gene Quinn states “Unfortunately, despite what you may have heard, there is no effective way to protect an idea through intellectual property law. Copyright protects expression and patent law protects inventions, and neither protect ideas. In both cases the idea is the first critical step, but without some identifiable embodiment of the idea there can be no intellectual property protection.”

• Personal information is also not created in vacuum, often multiple party's are involved. A husband and wife creating an intimate video, multiple uses on Facebook collaborating to share experiences through the “Wall” etc.

• These complexities are illustrated in the famous supreme court case of Haynes V. Alfred A. Knopf Inc. The case involved the publication of a book which chronicled the life of an abused African American wife. Ruby Lee Daniels Suffered gravely from her husband’s alcoholism and misconduct. Luther Haynes, Ruby’s husband sued her publisher under the public disclosure of private facts tort claiming that he had turned his life around and the ugly episodes of his life were entitled to privacy protection. Judge Posner in his majority opinion concluded that there could be no liability for invasion of privacy because “A person does not have a legally protected right to a reputation based on the concealment of truth and because the book narrated a story not only of legitimate but of transcendent public interest.”

• Professor Solove in his commentary claims “Although this case did not hinge on the shared nature of the information, it illustrates that personal information rarely belongs to just one individual; it is often formed in relationships with others. Ruby Daniel’s story was deeply interwoven with Haynes's story. Daniels had a right to speak about her own past, to have her story told. This was her life story, not just Luther Haynes's, In sum, understanding control as ownership presents difficulties in grappling with the unique shared nature of private information. A claim of privacy is not the same as a claim of ownership.”

• Some limit control over information conception of privacy to matters of intimate information. This can also be too broad a conception. For example preventing indecent exposure is not seen as the protection of privacy of the exposer but as the invasion of privacy of the public in general. Exposing one’s genitals to a medical professional for examination is also not seen as a violation of privacy, even when this is performed without one’s consent as they might be unconscious.

• Control over information conceptions are also too-narrow in the sense that they do not encompass aspects of privacy that involve a freedom from. As Theorist David O’Brien claims “Privacy is invaded not just by the loss of control over information but also by nuisances such as noises, smells and other noxious disruptions of one’s peace of mind. Examples include being forced to hear propaganda, being manipulated by subliminal advertisements, or being disrupted in a manner that thwarts one’s ability to think or read”.

• Control over information conceptions of privacy do also seem to emphasize heavily individual choice. Privacy is a complex societal architecture of information regulation where millions of actors share, manipulate withhold information as they go about their projects of self creation. Privacy is nowhere close to just being an matter of the exercise of individual control.

• In an era where information about a person can be obtained instantaneously from hundreds of sources, even if individual sources themselves did not reveal much information a compilation might reveal patterns which one might consider an invasion of privacy.

Personhood – The protection of one’s personality, individuality and dignity.• The conception of Privacy as personhood usually compliments

other conceptions of privacy and by itself is usually not viewed as an atomic conception.

• Philosopher Stanley Benn describes a Personhood conception of privacy succinctly “Privacy amounts to respect for individuals as choosers: Respect for someone as a person, as a chooser, implies respect for him as one engaged in a kind of self-creative enterprise, which could be disrupted, distorted or frustrated even by so limited an intrusion as watching”. Benn drawing from Sartre further explains that “being an object of scrutiny, as the focus of another’s attention, brings one to a new consciousness of oneself, as something seen through another’s eyes. The observed becomes aware of himself as an object, knowable, having a determinate character. The observed person is a fixed something – with limited probabilities rather than infinite indeterminate possibilities.

• Privacy in this conception is essential for freedom. For the mere gaze of the other restricts the certain possibilities of self creation

• In simpler terms, consider one of Sartre’s examples. A peeping tom looks through a keyhole while he is in the act of peeping his consciousness of himself does not change if he is not discovered. Once someone discovers him, their mere gaze changes the peeping tom’s conception of himself.

• In the same sense, mere government surveillance/threat of surveillance or regulation restricts a persons project of self creation. Certain aspects of the self cannot now be realized because he is no longer a pure object but now a subject.

• If one were watched by cameras all day long, like in London for example. Ones project of self creation might be totally different from if he/she were in New Delhi with no cameras. Public Spaces will be viewed totally differently with New Delhi offering a more fertile ground for self creation.

• The Supreme Court has embraced the personhood conception of privacy in many cases including the seminal one allowing abortion as a woman's right to privacy i.e. Roe V. Wade. In Planned Parenthood V. Casey the Justices in their majority opinion provided an elaborate explanation of what the constitutional right to privacy encompasses:

“These matters, involving the most intimate and personal choices a person may make in a lifetime, choices central to personal dignity and autonomy, are central to the liberty protected by the Fourteenth Amendment. At the heart of liberty is the right to define one’s own concept of existence, of meaning, of the universe, and of the mystery of human life. Beliefs about these matters could not define the attributes of personhood were they formed under compulsion of the State.”

• Here one aspect of privacy is conceptualized as the non interference of the state in matters that are crucial to defining one’s personhood.

• Theories of personhood also suffer from being too broad, because they often fail to articulate an adequate definition of personhood and thus their conceptualization of privacy is also vague.

• There also seems to be a slight logical problem with the various conceptions of personhood. Because the right to personhood seems to be both a positive and negative right. i.e. the state needs to prevent disruptive characters from infringing other person’s realizations of personhood. However by doing so the state can intentionally/un-intentionally impose a sense of what is more important and hence prevent an unlimited realization of personhood, which is exactly why personhood was conceived as an aspect of privacy in the first place.

• Philosopher Jed Rubenfeld explains this criticism more effectively.

• “By conceiving of the conduct that it purports to protect as ‘essential to the individual’s identity,’ personhood inadvertently reintroduces into privacy analysis the very premise of the invidious uses of state power it seeks to overcome. When the state endeavors to protect personhood, it must adopt and enforce its own conception of individual identity, impinging upon the freedom of individuals to define for themselves what is central to their identities.

• Nonetheless personhood is a powerful conception of what privacy is. In conjunction with other theories provides a strong framework for the universal conception of privacy.

• It is however also filled vagaries which make a concrete usable definition of privacy hard to formulate.

Intimacy – Control over, limited access to one’s intimate relationships.• Conception of privacy in terms of intimacy recognizes that

privacy is essential not merely for self-creation, but for human relationships.

• This conception of privacy consists of a form of limited access while it locates the value of privacy in the development of personal relationships.

• Political Scientist Robert Gerstein explains:

“We form relationships with differing degrees of intimacy and self-revelation, and we value privacy so that we can maintain the desired levels of intimacy for each of our varied relationships. Intimate relationships simply could not exist if we did not continue to insist on privacy for them. By focusing on the relationship-oriented value of privacy, the theory of privacy as intimacy attempts to define what aspects of life we should be able to restrict to, or what information we should be able to control or keep secret.”

• What is crucial in conceptualization of intimacy as privacy is the definition of intimacy. If one can lock down a precise enough definition, then such a conceptualization can be the corner stone of the concept of Usable Privacy.

• Political Scientist Inness, claims that Intimate matters draw “their value and meaning from the agent’s love, care or liking” This is the scope of intimacy. i.e. a subjects intentions if they stem from love, care of liking are intimate intentions where privacy should be respected.

• For theorist James Rachels “there is a close connection between our ability to control who has access to us and to information about us, and our ability to create and maintain different sorts of social relationships with different people.

• Fried and Rachels define intimate information as “is that which individuals only want to reveal to a few people.

• This seems too broad because intimacy stems from the act of caring, not mere sharing. As Jeffrey Reiman suggests –

• “The ability to love and care for others transcends the mere sharing of secrets, one ordinarily reveals information to one’s psychoanalyst that one might hesitate to reveal to a friend or lover, this hardly means that one has an intimate relationship with the analyst, what is missing is that particular kind of caring that makes a relationship not just personal but intimate”

• Various other attempts to conceptualize the word intimacy lead to similar problems where they are too broad. Without limitations in scope the word intimacy Is just another word for privacy.

• Privacy as intimacy conceptualizations are also too narrow in the sense that it ignores serious breaches of privacy. As political scientist Priscilla Regan describes:

“Computer databases post a significant threat to privacy but do not primarily affect relationships of friendship, love, and trust. Instead, these threats come from private and governmental organizations- the police, welfare agencies, credit agencies, banks and employers.”

Towards usable privacy.• Given the enormous difficulty in conceptualizing a not too vague

concept of privacy, which is essential for usable privacy; Professor of law Daniel J. Solove suggests that instead of conceptualizing privacy i.e trying to define it attempting to create a taxonomy of privacy would be more fruitful and yield concrete usable results.

• The taxonomy essentially groups activities that pose privacy problems and identifies different kinds of socially recognized privacy violations.

• Utilizing Wittgenstein’s idea of “Family Resemblance” Professor Solove creates a taxonomy. The essential idea in Family Resemblance is that as one creates groups one notices resemblances, similarities crop up which aids in classification. For example as we list the group “card games, board games, ball games etc” we see simalarities crop up which allows for classification. In this case when one builds a taxonomy, when confronted with a new candidate for a potential privacy concern one look at the other members and judges if there is a family resemblance.

• Professor Solove creates the following taxonomy consisting of four principle groups of activities:

1. Information collection

Surveillance

Interrogation

2. Information processing

Aggregation

Identification

Insecurity

Secondary Use

Exclusion

3. Information Dissemination

Breach of confidentiality

Disclosure

Exposure

Increased accessibility

Blackmail

Appropriation

Distortion

4. Invasion

Intrusion

Decisional Interference• Understanding privacy using a taxonomic framework

provides for a concrete method of classification that is not too narrow and not too vague. It is a real tool that can be used to make reasonable judgments as to the question of weather a certain activity might breach privacy, and it thus usable in real work scenarios to solve real world problems.

Bibliography• BOOK: Information Privacy Law By Daniel J. Solove (Author) and Paul Schwartz (Author) • BOOK: Understanding Privacy by Daniel J. Solove• http://en.wikipedia.org/wiki/Family_resemblance• http://en.wikipedia.org/wiki/Katz_v._United_States• http://en.wikipedia.org/wiki/Olmstead_v._United_States• http://groups.csail.mit.edu/mac/classes/6.805/articles/privacy/Privacy_brand_warr2.html• http://en.wikipedia.org/wiki/Samuel_D._Warren_(US_attorney)• http://en.wikipedia.org/wiki/Negative_and_positive_rights• http://www.va/archive/catechism/p3s2c2a8.htm• http://en.wikipedia.org/wiki/Universal_Declaration_of_Human_Rights• http://www.un.org/en/documents/udhr/index.shtml• http://en.wikipedia.org/wiki/Council_of_Europe• http://en.wikipedia.org/wiki/European_Convention_on_Human_Rights• http://en.wikipedia.org/wiki/Data_Protection_Directive• http://en.wikipedia.org/wiki/Fourteenth_Amendment_to_the_United_States_Constitution• http://www.dataprotection.it/the_right_to_privacy.htm• http://plato.stanford.edu/entries/privacy/• http://www.professorgreen.com/lakev.htm• http://en.wikipedia.org/wiki/Roe_v._Wade• http://en.wikipedia.org/wiki/Planned_Parenthood_v._Casey• http://openjurist.org/8/f3d/1222/haynes-v-alfred-a-knopf-incorporated• http://ipwatchdog.com/inventing/patent-ideas/