THE HISTORY OF THE PRIVACY ISSUE IN THE UNITED STATES AND IN ENGLAND IS TRACED, WITH REFERENCE TO EVENTS THAT GAVE RISE TO CONCERN ABOUT PRIVACY VIS-A-VIS GOVERNMENT INFORMATION SYSTEMS. THE RESPONSES OF THE COURTS AND LEGISLATURES TO THE PRIVACY ISSUE ARE EXAMINED, AND POLICY STATEMENTS ISSUED BY THE GOVERNMENTS OF THE TWO COUNTRIES ARE COMPARED AND CONTRASTED. IT IS NOTED THAT, DESPITE A COMMON CULTURAL AND LEGAL HERITAGE, ENGLAND AND THE UNITED STATES HAVE APPROACHED THE PRIVACY ISSUE FROM DIFFERENT PERSPECTIVES. THIS DIFFERENCE IN APPROACH HAS RESULTED PRIMARILY FROM DISSIMILAR POLITICAL AND LEGAL CONTEXTS. FOR EXAMPLE, UNLIKE THE UNITED STATES, ENGLAND LACKS AN EXTENSIVE BODY OF CASE LAW ON THE SUBJECT OF PERSONAL PRIVACY. IN GENERAL, THE BRITISH APPROACH HAS BEEN TO REJECT THE NOTION THAT THE RIGHT TO PRIVACY CAN BE REGULATED THROUGH CASE LAW OR BY STATUTE AND TO RELY ON THE PRINCIPLE THAT 'WHAT IS NOT PROHIBITED IS PERMITTED.' IT IS CONCLUDED, HOWEVER, THAT BOTH GOVERNMENTS HAVE RECOGNIZED THE NEED TO DEVELOP LEGAL AND TECHNOLOGICAL SAFEGUARDS FOR COMPUTERIZED CRIMINAL JUSTICE INFORMATION SYSTEMS, BUT HAVE FOUND THAT, DUE IN PART TO CONTINUING INNOVATION IN COMPUTER TECHNOLOGY, LEGISLATING CONTROLS HAS PROVED DIFFICULT. IN DEVELOPING NEW STANDARDS AND PROCEDURES FOR THE FUTURE USE OF COMPUTERIZED INFORMATION SYSTEMS, THE UNITED STATES AND ENGLAND ARE URGED TO KEEP DEMOCRATIC PRINCIPLES IN THE FOREFRONT OF THE DECISIONMAKING PROCESSES.