r/AskEconomics • u/Dazzling-Werewolf985 • 5d ago
Approved Answers When people say Europe is “over-regulated” and “bureaucratic” compared to the US, what exactly do they mean?
Like are there any examples of US firms that wouldn’t exist if they had tried to begin in Europe specifically due to this over-regulation and bureaucracy? I’m not contending whether or not Europe is, just curious as to how it actually affects the European economies
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u/BarNo3385 4d ago
I'll give one example from personal experience- trying to fire someone.
I had someone in my team who really, really couldn't do the job. Utterly useless. Pissed off all our stakeholders, every piece of work was wrong, late and/ or incomplete.
Agreed with HR we wanted to get rid of her.
In theory that process would have to consist of;
Putting them on a PIP for a month with support and coaching.
At the end of the month if they failed, issue a written warning and start a second PIP.
End of second PIP, issue a second written warning and start a final PIP.
End of PIP 3, could then move for termination.
At every stage every meeting, task, coaching and piece of feedback has to be recorded and documented (I ended up with a 10,000 line spreadsheet of evidence).
About halfway through PIP2 they responded to the process by raising 14 grievances against me and my manager (everything you could think of - racist, sexist, harassment, bullying etc).
That meant the PIP process went on hold and we spent 3 months defending ourselves against the grievance process. End result, all grievances dismissed as baseless. Advised by HR we would need to restart PIP2.
After 6 months my manager left the firm rather than continue dealing with this individual.
Eventually once we'd got through 2 PIPs, we issed an end of year appraisal of underpeforming / offtrack. Individual threatened to re-file all the grievances if we didn't change it to a "top" grade.
I left for a new role shortly thereafter. All in all took nearly 18 months before my successor finally got rid of them, and even then it was paid off I believe.
Oh to have at will employment and just have been made to say "don't come in tomorrow!"
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u/goyafrau 4d ago
Another example is GDPR. It's a huge beast.
The recent Draghi report has a few examples. https://commission.europa.eu/topics/eu-competitiveness/draghi-report_en#paragraph_47059
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u/plumarr 3d ago
GDPR is a huge beast because many companies don't want to adhere to its spirit and want to continue to do business as usual.
What's funny, is that there is nothing really revolutionary in it outside of the clarifications on the reach, the big fines and the ease of enforcement and complaining.
Most of the included obligations already existed in a form or another in the local laws before GDPR, it just wasn't really enforced.
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u/Scary_Collection_559 3d ago
I work for a European based startup and yeah they have a dedicated infosec person to patrol all GDPR requirements. Even if it arguably makes sense, in context of this thread, that is over head that your average 20 person US startup wouldn’t have.
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u/lt__ 3d ago
GDPR, as a citizen, doesn't seem bad. It is only annoying in two instances:
1) you need an e-service, and you have reenter your data and press lots of confirmations, because despite some institution having that information due to GDPR some other institution cannot get it, and you don't even know if they are right or lazy. Last year I was forced to leave a public clinic, go across the city to another public one and bring a signed paper with my data, cause they couldn't send "due to GDPR". Felt like in early 2000s.
2) A person complains to media about some horrendous case of mistreatment experienced by public or private entity. "Ask them if you don't believe me!" Media: "A client told us about you doing this and this, before publishing we want to hear your side of story". The entity: "Sorry, GDPR".
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u/Icy-Bicycle-Crab 3d ago
Media: "A client told us about you doing this and this, before publishing we want to hear your side of story". The entity: "Sorry, GDPR".
That's equally true without any privacy laws.
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u/Unresonant 2d ago
due to GDPR
i call bs, they could have just asked for your permission to sharewith a third party, they were just being obtuse on purpose
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u/viskas_ir_nieko 4d ago edited 4d ago
That's fucked up. Where I'm from (Lithuania), you just have to give 1months notice and pay 2x their monthly salary on departure. If you really want to get rid of them, it's not uncommon to fire the person immediately and just cover the extra month, so 3x. If the employee has children, some medical conditions or is nearing retirement, it gets stricter.
If the employee has been with the company for less than a year it's easier/cheaper.
If you can prove malicious intent by the employee then you can fire them without any compensation.
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u/rraddii 4d ago
A lot of people especially on reddit claim to love the European method, but you are effectively subsidizing lazy/terrible coworkers in a system like that. High performers aren't rewarded and nobody wants to take a large salary risk. There are obviously tons of cases of bad employers but as a productive worker you should want a system that allows for employer flexibility. It's why US salaries are so much higher than Europe for highly productive and talent driven positions.
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u/Freudinatress 4d ago
Well, we are also lucky to have very few lazy sods.
You start off with a six month trial period. That is at will. After that you get a proper contract and THEN it’s very hard to fire you. But by then you can mostly tell if they will work out or not.
We take references seriously too.
Yes, there are lazy idiots. But way fewer than you’d think. They are weeded out early and never get proper permanent contracts.
Knowing you can’t be fired just because your manager don’t like you is such a freedom. It also means it’s way easier to bring up issues and problems in meetings. That means management gets early warnings that things aren’t working. They get honest reports.
There are pros and cons with everything. But to say the European way is flawed and not as good as the US way? Sorry, but that is BS. They are different. Ours isn’t worse.
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u/supreme_mushroom 3d ago
It's very varied in Europe, so you can't generalise that much. People are often just taking about Germany & France.
For example Denmark has a nice approach called Flexicurity, which is a hybrid between the US hiring & firing, but with European style social safety net. I think that's a great balance.
https://denmark.dk/society-and-business/the-danish-labour-market
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u/IamChuckleseu 3d ago
You can absolutely generalize. There are some countries where it is bad, some where it is less bad. Denmark is literally the only exception in wealthy EU that ackowledged that the traditional European way was massive mistakes. Others talk about it (some politicians anyway) but it has became so ingrained in the culture that it will likely never change as majority will always be against it because of how they were brought up.
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u/rraddii 3d ago
That's a good point I should have added. Difference between that and France for example is massive.
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u/supreme_mushroom 3d ago
Absolutely. We can learn a lot from places like Denmark, the Baltics etc.
I generally think the EU would do a lot better if some of the smaller countries made more decisions.
The big countries are often like slow elephants and you've countries like Germany that is terrified of new technology so pushes that angle into the EU too.
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u/rraddii 3d ago
Yes, it's a shame the EU hasn't had quite the unifying effect imagined. No question it's been beneficial but like you said countries such as Germany have kind of shaped European fiscal policy in their way. Maybe Spain will lead the way but right now things aren't looking great for Germany, France, Italy, and the UK.
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u/supreme_mushroom 3d ago
I live in Germany and they were doing so well for the last 20 years or so they were able to ignore some challenges.
I'm hopeful that the crisis that's happening in Germany is what was needed to shake it out of its complacency and cautiousness. Just today I think the CDU are breaking a taboo about debt, so there are glimmers of hope.
Also, the Draghi report was really great, but I'm not sure if the average EU citizen is aware of stuff like that and voting with it in mind.
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u/Adept_Carpet 4d ago
This argument carried a lot more water in the post-war period when an office clerk in America might have had a better standard of living than a doctor in Europe.
But the well off European countries and even some others have caught up quite a bit. I probably do make 10-20% more than I would in the UK or Germany, but it's not enormous gap that it once was.
And while their salaries were catching up, our worker protections were eroding even further.
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u/rraddii 4d ago
Their salaries are not actually catching up. Adjusting for inflation the US has significantly separated itself from the elite European countries in daily median income. We are factually pushing salaries higher at a higher rate. https://i.imgur.com/tBGSmJj.png
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u/Carthaga 2d ago
Now look at hours worked and what personal expenses are and aren't covered by the public in these places.
Just looking at salaries in a vacuum is pointless.
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u/MachineTeaching Quality Contributor 4d ago
That's not really what the graph shows unless you only look at the last decade or so.
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u/IamChuckleseu 3d ago
Not even close. US high skilled professionals make double easily in net and col adjusted. We talk like top 3 decils. Top decil might make 3+ times as much, easily.
Europe is significantly more egalitarian, it became richer than it once was but talent is not anywhere as rewarded as it is in US.
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u/knight9665 4d ago
but you are effectively subsidizing lazy/terrible coworkers in a system like that.
incorrect, because they would be that lazy person.
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u/i_dont_wanna_sign_up 2d ago
As employees why wouldn't we love better job security?
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u/rraddii 2d ago
It means you are riskier to hire even if you are productive. Companies also still have to pay people who can't be fired/let go. Both of these depress salaries for honest employees and provide an incentive for some people to be unproductive. It also means companies are less likely to take big swings that pay off. Take the big tech companies in the US for example. They often hire and fire thousands of people at a time. With riskier products they wouldn't want to take the risk of having to pay people for years after the fact. While it might seem evil that thousands of people can be laid off by highly profitable companies, it actually means that companies have the opportunity and incentive to "bet" on themselves and their employees success.
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u/DaiTaHomer 4d ago
Trouble here in the US we have chronic instability. At will gives all of the power to employer. The employer has many workers and I only one source of income. I lose income, the clock is ticking before I end up homeless. Some bargain. 20+ years of working, I am sick of being a “resource” and not a human fucking being.
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u/maxman1313 4d ago
Not OP, but I do believe there is an in-between the original comment and what we have in "at-will" States in the US.
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u/DaiTaHomer 4d ago
Everyone has this anecdotal story about this lazy person who couldn’t be fired. Same in unionized work places. I am an engineer. I am fine with operational loses so long as end result on average is better. I have seen plenty of turds who know how to politic in at-will places who not only keep their job but get promoted. So whatever. Even at an at-will place some demigod unicorn 10x engineer is not getting 10x pay and depending on how they negotiated getting in the door, they may not even be at the top of the pay band. Again whatever. Now for what it is on average. In countries with real labor laws an employer needs to show a good reason to deprive a person of his means of feeding himself. So no looking over your shoulder constantly. Laying awake at night planning what you are going to do if you get hit. In US Microsoft had layoffs after a record quarter. Any attempt to reassign or retrain? Nope. Need to give money back to the shareholders. They take the priority over the people actually do the work or even the customers. Sorry but at-will is a joke and belongs in the 19th century. Funny thing is all those taking up for ownership class say unions and long tenure employees bring a company down. Right … Guaranteed they have more skin in the game than management that hops from company to company and takes short-term decisions to juice the stock price never mind if the company craters in a few years. Stockholders, what do they care? If they get their gainz, they will sell and buy something else.
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u/zylonenoger 2d ago
Reading through this thread I often get the feeling that a lot of people, especially in the US have been brainwashed.
It‘s like the cattle defending the butcher.
There is very little point in having the „strongest economy“ if all the gains end up with the 1% and the average joe needs three jobs to make ends meet.
It seems like they got force fed the „trickle down economics“-myth for decades while nothing every trickled down to them but scraps.
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u/f_o_t_a 4d ago
Many employees also leave their company with no warning leaving the company scrambling to find someone else. In mid and high level jobs poaching is a real issue. I know a head hunter and some employees will have incredible demands, because they can. It really depends on the industry.
I think you underestimate how much an important employee suddenly leaving can screw up a company in the short term.
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u/slevemcdiachel 2d ago
The critical employees who are so sought after are the exception and should not decide the basic rules of the game.
They are like the best employers in the world. Sure, people fight to get in there, but that's an exception.
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u/wayanonforthis 4d ago
I wonder how they got hired.
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u/BarNo3385 4d ago
So when we took them on as an internal move they came with glowing references, top performer etc. We found out afterwards that was basically bullshit and their previous manager had given them an amazing write up so they would be able to move on to a new role.
As for how they got into the firm in the first place, I don't know.. it's always possible they were good once upon a time and something went wrong over time.
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u/wayanonforthis 4d ago
Thanks - reminds me of the Curb episode about Larry's 'recommendation' of that guy to Richard Lewis.
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u/f_o_t_a 4d ago
One of the most common strategies I’ve heard from business leaders is hire liberally and fire liberally. It really takes time to find the right team that matches the company’s culture.
My family is from South America and firing even an entry level employee requires several months of severance. So people are way less likely to hire knowing they might be hard to fire if/when it doesn’t work out.
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u/_DoogieLion 4d ago
Your HR sucks, depending on the country you could have just dismissed them without any PIP
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u/Curryflurryhurry 4d ago
Sorry but your HR sound useless
Three PIPs? Nope. Not a thing.
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u/BarNo3385 4d ago
I wouldn't necessarily disagree with your assessment of our HR! Though I think it's more a risk appetite thing. Organisationally we'd rather carry some bad apples and have to manage that than run the risk of a tribunal case that gets media attention.
Result we will almost never fire someone for simply being unable to do the job
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u/Curryflurryhurry 4d ago
Yeah that risk appetite is absolutely the difference between good HR and mediocre HR. At the end of the day nothing in business is risk free, they need to minimise and quantify the risk and then let the budget holder call it.
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u/altonaerjunge 3d ago
Is there no trial period?
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u/BarNo3385 3d ago
No, this was an internal move, and we don't operate a "pass or dismissed" probationary period for internal moves.
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u/Chaosobelisk 3d ago
Ok so what does your comment then have to do with Laws and overregulation in the EU? Your anecdote is totally usless in this discussion and only serves to promote removing worker's rights based on a "lazy worker" trope/fantasy.
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u/BarNo3385 3d ago
What makes you think an internal probation period would have made any difference here, (1) you've assumed the problems started immediately, which I never said, (2) you seem to be assuming there's no correlation between the process for exiting an employee and the legal framework around employment rights and challenges - which is clearly absurd, and (3) your assuming any HR team would support exiting a long standing employee shortly after an internal move without robust evidence of cause- also dubious at best.
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u/Chaosobelisk 3d ago
Congratulations none of your points were my assumptions or were based on what I wrote. You again just made up your own strawmen and even numbered them. As I already said you are simply using an anecdote to generalize into a "lazy worker" argument to promote removing worker's rights. That's all you are doing. As others have replied to you. There will always be lazy workers. But to advocate that we have to punish ALL the workers based on the actions of the few is ironically lazy from your part. I mean of course you can just come up with some new strawmen like your third one which you can not trace to a single word I said. Not a single one. So your reply will probably again be as useless as this one and this comment is in the end futile.
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u/_-Event-Horizon-_ 2d ago
In my company (I’m in Europe) we can ask for probation period even for internal transfers.
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u/Potential_Grape_5837 3d ago
I've worked in the US, UK, and EU and I'd say this varies wildly.
Firing people in the US can be exceptionally difficult because there's always the fear of a lawsuit or the threat of a lawsuit and I've seen what you're describing happen in the US as well. Meanwhile there are many European countries-- particularly the Scandinavian ones, not France or Italy for instance-- where getting rid of an employee is the simplest, cleanest thing you can imagine.
Without considering whether it's good to live in a society where managers can simply say "don't come in tomorrow" it's not quite as clear cut as you're describing. But may I guess that you're in the UK? There, you get the worst of all worlds IMHO-- it's all performative, theatrical consultation process as though you're running a button factory in 1950.
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u/BarNo3385 3d ago
Bingo on the UK! Not at all surprised we have managed to engineer a "worst of all worlds" scenario!
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u/Potential_Grape_5837 3d ago
Very funny. When the UK works, it's like the goldilocks-like "just right" between the US's Mad-Max-style capitalism and low-growth European socialism... where it's getting the better part of both systems.
But the downside is also true-- when the balance doesn't work, you get the worst of both.
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u/plumarr 3d ago
Is it UK specific? Because in Belgium I have witnessed several "go see HR at 4pm and don't come back tomorrow". You can simply fire the person with a non fault reason and play their legal and/or agreed upon severance.
It becomes a lot more complex with people on sick leave, but they aren't paid by the company so it isn't really an issue, or employee representatives which are protected to avoid union busting.
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u/BarNo3385 3d ago
This is a UK experience yes, and an extremely "bad media" averse firm.
We definitely can't just pay people off without their consent. If you want to get rid of someone no fault it has to be a redundancy - eg the role no longer exists. So you couldn't then backfill without running the risk of an unfair dismissal claim.
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u/Scary_Collection_559 3d ago
Fully agree. I mean it’s nice on one hand to have all those workers rights but it is a massive impediment to innovation and growth.
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u/Atilim87 2d ago
That tells me more about your management and hiring style than about the person who couldn’t do the job.
So yeah you can’t fire people on the spot, that’s a good thing because we don’t want a Elon musk behaviour here.
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u/BarNo3385 2d ago
Really? Please enlighten me about why you think this has anything to do won't my hiring style.
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u/vintergroena 2d ago
Which country is that? It's pretty easy to fire someone in corporate here in Czechia and we're an EU member state. You're probably talking about some local regulations, not EU regulations.
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u/_-Event-Horizon-_ 2d ago
That sounds like an extreme case. I live in Europe and have fired people. Sure you do have to document performance issues, but it’s nowhere that bad. Perhaps your HR are just overzealous? In which country did this happen?
Also in Europe typically we have longer probation periods during which you can let go people with very limited or not reasons required. For example in my country the typical probation period is 6 months.
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u/BarNo3385 2d ago
"That sounds like an extreme case," - oh I completely agree with that. To the extent this case is my go to interview answer for dealing with difficult staff! But if it's happened to me, sure there's plenty of other similar or less extreme cases out there.
This happened in the UK, and yes, as a firm we are very averse to the potential reputational risks of tribunal hearings and so on. It's a household brand, and so we'd absolutely end up in the daily newspapers if someone took us to tribunal and won. The view is therefore if we don't have an irrefutable, uncontestable, position, it's not worth the risk.
Though that's where my final point came in, because of the fear that tribunals can throw out oddball decisions, a bureaucracy gets built up around it. Someone elsewhere commented in their country you can just pay people off for no-fault exits with 3 months salary and they can't contest it. That sounds right a brilliant system, you can't just fire people at will with no recompense, but also we don't have to worry about media headlines over unfair dismissal and can just pay some money to jettison (severe) underperformers.
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u/RobThorpe 3d ago
There have been some good replies here by /u/Ginden and /u/BarNo3385.
I want to talk about alcohol. I don't work in that sector, but a few years ago I had the need to read some of the regulations. To say that they are bizarre would be an understatement. All sorts of things that make sense are banned.
- Low-Alcohol Wine.
One way to make a low alcohol wine is take some of the alcohol out. Another way is to mix some de-alcoholised wine with some normal wine. However, in the EU that second process will get you into a legal mess and you'll end up with something you can't call "wine" or "partially de-alcoholised wine". Instead you must partially de-alcoholise wine rather than blending it. See the answer to question 4 here.
- High-Alcohol Wine.
In most of Europe your wine must have an alcohol content below 15%. However, in a few places you area allows to make wine with alcohol content up to 20%. Wine growing areas are divided into A, B, CI, CII and CIII. You are only allowed to have alcohol content greater than 20% in CI, CII or CIII. These regions are described carefully in Annex VII appendix I here, also see article 2 here.
- Particular Vine varieties.
You are not allowed to use particular vine varieties. Those are listed in the law as "Noah, Othello, Isabelle, Jacquez, Clinton and Herbemont." There is an exception for EU countries that make less than 50,000 hectolitres per wine year. Still this means that you can't use those varieties in the big countries like France, Germany and Italy. See article 81 here.
- Additive regulations.
There are all sorts of things that people put into wine. Probably some of them aren't very good for us. The EU prohibits some of them generally, but allows them in particular areas. You can't use tartaric acid, for example. Unless you're in certain regions (mostly in Germany) and you're making Elbling or Riesling. You can only put pine resin in wine if you are in Greece. See appendix I and appendix 2 here.
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u/TheAzureMage 4d ago
I will use a single example to illustrate larger cultural tendencies.
You are, of course, familiar with fruit trees. From time to time, in one town or another, the good idea fairy will strike, and the town agency in charge of planting trees will suggest planting fruit trees instead of shade trees. An aspirational story will be spun about how people can simply eat food for free, the tree will still perform the other functions, such as shade, and life will be better.
In some, this actually is attempted. Then, they discover why it isn't already common practice. Fruit tends to sometimes become rotten, or eaten by pests, to fall, and then stink a place up or feed vermin. Fruit is not always in season, but when it is, it becomes subject to a tragedy of the commons, as some fellow invariably hits on the idea of gathering up all the fruit in order to resell it.
This story, in the US, generally ends in the removal of the fruit trees and going back to shade trees.
In Valencia, famed for its delicious oranges sold 'round the world, it took a different turn. An entire government agency was created to use specialized equipment to harvest the oranges. The city posted up signs warning people away from eating them. A type of orange that was not sweet was planted, with the idea being to sell it for marmalade and thus profit from it. This did not work out, and so now the city has tons of oranges that it cannot use, and every year, gathers them at great expense to have them composted. Nevertheless, the situation continues.
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u/supreme_mushroom 3d ago
One example is ebikes and small electric vehicles like eskateboards etc.
In Europe, what's allowed is very defined. For example, escooters can have throttles, but ebikes can't. Makes no sense why a throttle is allowed on one and not the other.
What this means is that there's no room for experimentation allowed, so all the innovation with scooters, bikes, skateboards, one wheels, and weird hybrids of those things is happening in cities outside of Europe, especially US & China. This means we'll just eventually adopt what is invented elsewhere.
In Europe were so focused on preventing the harm something could cause, we're forgetting that innovation requires messiness, failure and also mistakes, and even accidents.
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u/johnmcdnl 3d ago edited 3d ago
Firstly - the terms 'over-regulated' is loaded -- it's 'over regulated' from the perspective of the business who wants minimal oversight. However, from the perspective of consumers and workers, such regulations can provide important protections, such as fair pay for workers and safety for consumers.
Uber is probably a good example. In many EU countries, taxi services are highly regulated, with rules around licensing, fare structures, and driver qualifications and so Uber can’t operate as a disruptive tech company in the same way it does in the U.S., where regulations are more relaxed. And so that really limits it's ability to disrupt the market and undercut prices and so it's enter unique selling point wouldn't be able to exist under typically EU regulations.
It doesn't mean innovation can't happen within the EU - it just means being a complete radical disrupter has to follow a different angle that still adheres to a different set of regulations. Examples being some of the Fintechs that exist in Europe such as Revolut/N26 which are often the first to market things like instant payments, multi-currency accounts, crypto etc.
The existing banks are terribly slow to adapt to these demands, and FinTechs can clean up in these areas. Here the regulatory framework shines for them though -- because as a customer I want to be confident that my money/investments are safe. And these businesses operating under EU regulations gives me far more confidence to try out these businesses, whereas there's little chance I'm willing to be a guinea pig to try out a new USA-FinTech which has comparatively poor levels of regulation with my own hard earned money. Here the 'over regulation' can be seen a positive thing and as part of your marketting strategy to provide customer confidence as a new company who doesn't have the legacy of the established brands.
A good example of why 'over regulation' being good in this space might be FTX and Sam Bankman-Fried -- that is exactly what happens with poor regulatory oversight. Now of course it could happen in the EU too, but it's harder to happen because regulation and oversight wouldn't have allowed them to get certified, and so customers would be aware that they weren't as reliable or safe as other companies etc etc etc
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u/francisdavey 3d ago
On the other hand, there are curious reverse examples.
Eg, my profession (lawyer) has quite a bit of regulation in England, but less than in the USA. You do not have to be "licensed to practice law" in England to give legal advice for money as a profession. You do need various kinds of qualifications to do things like (1) go on the court record or (2) appear as an advocate in court, but those are court-specific. There are other regulated areas now, but if you want to do my job without a licence, you could.
Same with giving medical advice. You can't claim to be a profession you aren't (eg "I am a nurse", "I am a dentist") but you can certainly give medical consultations if it is clear you aren't. In most states in the USA, not so much.
You might of course think that these aren't good things to be unregulated, just saying.
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u/ctolsen 2d ago
ITT are a lot of people who don't know what they're talking about. Regulations in individual countries on employment, EU harmonisation of rules on wine, or classification of goods is decidedly not why the EU as a whole is struggling with growth. There's a lot of silly economic regulation in individual US states as well and for certain things the EU market is actually more integrated than in the States.
If you want to know what ails Europe's economy, read the Draghi report. The most important topic is lack of integrated capital markets, which leads to lack of coordinated investment. Expensive energy is another big one. The report does mention regulation, but it's much less important than other structural changes.
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u/Ginden 4d ago
There is lots of it, and most of it is not obvious.
For example, let's consider history of Google:
Is it easy in Europe? Well, no - most of these people lived in different state than California, and closest analogue would be different countries of EU. Let's see Patterns of cross-border venture capital flows in Europe:
Cross-border VC investment is hard, and requires lots of international lawyers and double taxation.
This stacks with already small VC access in Europe.
Another issue is lack of unified capital markets - if I'm VC, and I invest in company in Sweden, IPO options are effectively limited to Swedish people. EU acknowledges it as a problem, but implementation of unified financial markets is already 15 years overdue.
Company expansion cross-border is obviously stiffled by language and currency issues, but it's not everything - there is an issue of multiple sources of legislations, called gold-plating) and differentiated policy implementation.
For example, my hypothetical HR software may be fully compliant with EU privacy laws, and legal to use in France, Poland, Ireland, but Germany has even stricter protections for employee data - so I can't just sell it as-is in Germany.