نوع مقاله : مقاله پژوهشی
عنوان مقاله English
نویسندگان English
The European Union and the United States, as two major global actors, have adopted different approaches to cybersecurity regulation that significantly impact network security, privacy protection, and data safeguarding. Given the sharp rise in cyber threats and sophisticated attacks, the importance of a comparative study of these two approaches to identify strengths and weaknesses of each legal system is increasingly felt. This research aims to provide a comparative analysis of cybersecurity policies, laws, and frameworks in the European Union and the United States. The research method in this article is descriptive-analytical, based on documentary and comparative study, examining legal sources, official policies, governmental documents, and prior research. Findings indicate that the European Union emphasizes user privacy and enforces stringent regulations such as the General Data Protection Regulation (GDPR) to advance cybersecurity within the framework of civil rights and personal data protection. In contrast, the United States adopts a more national security-oriented and flexible regulatory approach, especially through sector-based policies and voluntary standardization, aiming to foster a dynamic environment for technological development and cyber threat response. These differing approaches bring specific advantages and limitations, ultimately affecting the quality and effectiveness of cybersecurity management. The innovation of this study lies in its comprehensive and comparative analysis based on up-to-date official documents and laws, which can assist policymakers and legal experts in enhancing cybersecurity frameworks.
کلیدواژهها English