when confronted with the police. A recent notable occurrence of the conflict between law enforcement and a citizen in terms of digital privacy has been in the 2018 case, Carpenter v. United States (585 U.S. ). In this case, the FBI used cell phone records without a warrant to arrest Timothy Ivory Carpenter on multiple charges, and the Supreme Court ruled that the warrantless search of cell phone records violated the Fourth Amendment, citing that the Fourth Amendment protects "reasonable expectations of privacy" and that information sent to third parties still falls under data that can be included under "reasonable expectations of privacy". Beyond law enforcement, many interactions between the government and citizens have been revealed either lawfully or unlawfully, specifically through whistleblowers. One notable example is Edward Snowden, who released multiple operations related to the mass surveillance operations of the National Security Agency (NSA), where it was discovered that the NSA continues to breach the security of millions of people, mainly through mass surveillance programs whether it was collecting great amounts of data through third party private companies, hacking into other embassies or frameworks of international countries, and various breaches of data, which prompted a culture shock and stirred international debate related to digital privacy. Internet In the European Union (EU), personal data, in whatever form it is received, data protection rights must be respected by law. This also applies to companies based outside of the EU which conduct business inside the EU. Historically, the United States has disparate state and federal laws governing Internet privacy, with much left unregulated. While data privacy protection laws can grant individuals rights to control their data, enforcement is increasingly complex. A variety of data may be covered by specific laws, such as HIPAA, FCRA, FERPA, GLBA, ECPA, COPPA, and VPPA. Legal discussions of Internet privacy The Internet has brought new concerns about privacy in an age where computers can permanently store records of everything: "where every online photo, status update, Twitter post and blog entry by and about us can be stored forever", writes law professor and author Jeffrey Rosen. One of the first instances of privacy being discussed in a legal manner was in 1914, the Federal Trade Commission (FTC) was established, under the Federal Trade Commission Act, whose initial goal was to promote competition amongst businesses and prohibit unfair and misleading businesses. However, since the 1970s, the FTC has become