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The United States and Europe stepped up cooperation on security issues after Sept. 11, 2001. But that doesn't mean they agree on everything. The latest point of friction: What are the rules when it comes to privacy rights?

The revelations about the National Security Agency's surveillance programs not only touched off a ferocious debate in the U.S. but also struck a nerve in Europe.

The Europeans appear to be reacting mostly to the reports that the NSA tapped the servers of Google, Facebook and other Internet companies for personal data. The companies have hundreds of millions of users worldwide, including in Europe.

And just as there has been mixed reaction in the U.S., the same is true in Europe.

In Britain, the public has become accustomed to the widespread use of surveillance cameras. The reaction there to the NSA story is along the lines of "What on earth did you expect?"

Germany, however, has wrestled with memories of a police state under both Nazi rule and Stasi surveillance in East Germany during the Cold War. The reaction there has included a fair amount of outrage.

As The New York Times reports, since Sept. 11, the two sides have argued over "access to interbank transfer data and payments (a program known as Swift), and over the provision of passenger lists for airplanes flying to the United States from Europe. (France and Britain have similar requirements for planes flying there.)

"And there are continuing debates over whether individuals have the right to expunge data they posted in earlier, less circumspect days — what the French call 'the right to be forgotten.' "

Different Notions Of Privacy

J. Trevor Hughes, president and CEO of the International Association of Privacy Professionals, says that the U.S. and Europe view privacy in different ways.

"Europeans think of it as a fundamental human right, connected to a sense of dignity," he says. "In the U.S., we think of it in terms of liberty and response to harm."

And, Hughes says, those differences shape the way the U.S. and Europe approach privacy-related laws. The Europeans take a more broad-based approach, while the U.S. tends to look at specific cases and how it might have an impact on the marketplace.

Impact Of NSA Revelations

Hughes says the revelations about the NSA could affect a free trade agreement being negotiated between the EU and the U.S. It could also, he says, increase momentum for the passage of an EU privacy directive that would replace one that dates to 1995.

That measure set a basic framework but left it up to individual member states to craft their own specific legislation.

"The directive is more a floor than a ceiling," says Joel Reidenberg, a professor at the Fordham University School of Law.

The new measure is considered more far-reaching. Here's The Times reporting about it in February:

"Several proposals would go well beyond the voluntary policies of companies like Google. They would require companies to obtain permission before collecting personal data and specify exactly what information will be collected and how it will be used. If asked, companies would have to provide users with data that has been collected about them and allow them to fix mistakes. One proposal would include a so-called 'right to be forgotten' that would make it mandatory for companies like Facebook to delete all information about users who want to wipe the slate clean."