Comparative Study of Standards for Government Access

Governments around the world have long sought access to personal information about individuals for many purposes, including to deliver social services, to support regulatory regimes, and for law enforcement and national security. Government appetite for information about individuals has intensified in the 21st century, fed by concerns about crime, terrorism and cybersecurity. At the same time, there has been an explosion in the volume of digital data routinely generated, collected, and stored about individuals. Most of this data is collected and stored by businesses in the course of providing services.

Worldwide, similar questions are being asked: What are the standards under which governments claim access to such data? What are the legal rules for private sector compliance with such requests? When can governments demand that corporate systems affirmatively facilitate access?

In this resource, funded by The Privacy Projects, we present comparative information on these questions from a cross-section of countries. Some common themes emerge, as well as interesting differences.


Compares the basic framework for access to communications in each country.


Outlines the basic framework for access to other business records, country by country.


Describes the standards for government access by law enforcement agencies.


Describes the standards for government access by national security agencies.