“ The most important differences among the crimes against privacy in the various data protection laws emerge when the penal provisions are analysed in detail. Such a comparative analysis should differentiate four main categories of criminal privacy infringements, which are to be found particularly in European privacy laws:
The first main group of crimes against of privacy relates to infringements of substantive privacy rights and includes such acts as illegal disclosure, dissemination, obtaining of and/or access to data; unlawful use of data ”

“ In some countries, especially Canada, Japan and the United States , criminal law is not widely used for privacy protection. In other countries, the criminal law includes comprehensive lists of severe criminal offences that refer to many of the actions regulated by administrative law. ”

“ As a result of the uncertainties in the substantive provisions, many legal systems rely to a great extent on a second, and additional, group of offences and are directed towards enforcing various formal legal requirements or orders of supervisory agencies. ”