It's that time of year when I go back for a visit with my family in the States. There wasn't a lot of holiday spirit in the Raines family this year as I learned that both my nephew and sister had just been "right-sized" in the interests of enhancing investor value. To the uninitiated, that means they just lost their jobs. Evidently they weren't alone as over 1,250,000 Americans also lost their jobs in the last three months of the 2008. And the worst is yet to come as I read another report from an economist that predicted the closing of 70,000 American retail outlets in 2009. Happy New Year, everyone!All this holiday cheer got me to thinking about the rather stark contrast in work place rights between Europe and the United States and the role corporate security plays in enforcing or infringing those rights. As a point of comparison, I thought I would take rundown of the basic civil rights in a democratic society compare how these rights play out in the European and U.S. work places.First, consider freedom of speech. In theory, you have the right to say what's on your mind in the workplace in both the U.S. and Europe. They are both democratic societies that respect the notion of freedom of thought and speech. In practice, however, I find my European colleagues to be much more likely to complain about working conditions and to openly criticize management. Of course, the reason is partly cultural, but I think the difference stems primarily from the fact that in the United States in many non-unionized, private companies, management can let workers go without advance notice or reason. Given that fact that the large majority of Americans get their health insurance through their employment, a termination could genuinely be life threatening. Thus, many American workers prefer to accept whatever indignities are pushed upon them rather than speak out and take the risk of losing their jobs. Fear is a strong motivator.In Europe, on the other hand, the European Convention on Human Rights (ECHR) guarantees basic rights to European workers. The Convention was adopted under the auspices of the Council of Europe in 1950 to protect human rights and fundamental freedoms. There are 47 European countries which belong to the Convention.As it affects the workplace, ECHR article 6 guarantees the right to a fair hearing for unfair dismissal and article 11 guarantees the right to freedom of assembly and freedom of association including the right to form unions. With union protections and rights to appeal, European workers are not subject to arbitrary dismissal from management. Not surprisingly, in European workplaces, I found workers much more willing to voice their opinions even when they run contrary to the ideas of management.Next, consider the right to privacy in the workplace. In the United States you often lose your right to privacy when you walk in the door on the first day of work. Workers can be subject to drug testing at the time of their hire and, if the company desires it, at random times from that point on. Emails and any personal information generated on company computers belong to the company and can be reviewed. Security cameras are in the work place not just for security but the digital images are often used as evidence to discipline employees. In Europe, privacy is considered a fundamental human right. ECHR Article 8 protects European workers' right to privacy in their correspondence. Thus, monitoring of emails, phone conversations and internet usage; the use of intrusive CCTV coverage or vehicle tracking devices; or subjecting employees to searches or to drug or alcohol testing, is sharply curtailed if not outright prohibited.Hence, employers cannot read the personal emails of their employees even though the email was created, delivered and stored on company property using company equipment. Employers also cannot have security cameras in the work areas monitoring the employees at their desk. The last private American company I worked for did precisely that. If an employee was found on camera to be resting their head on their desk for a prolonged period during business hours then that was a cause for dismissal. Needless to say, no one in the company believed in "power naps."I do not mean to paint a too rosy picture of work life in Europe. You have petty politics, gossip, bad and good bosses in Europe the same as in the United States. But in the area of worker rights, the difference is truly stark and that, in turn, it affects the responsibilities of the security function in enforcing those legal rights in the workplace.In March, 1946 Winston Churchill delivered a speech at Westminster College in Fulton, Missouri in which he famously declared that an "iron curtain" had descended which separated the free democratic countries of the west from the Soviet dominated, communist countries of Eastern Europe. This figurative image became the defining metaphor of the Cold War to outline the differences between the liberties enjoyed in the free west and the lack of those same freedoms in the Eastern Bloc. Having worked in both Europe and the United States, I can clearly see a similar iron curtain of workplace liberties now dividing the two regions. The difference is, this time theUnited States is on the wrong side of the iron curtain.Paul Raines is an American CISO working in Europe.