Different Histories, Common Future? UK and German Policy Convergence on Passenger Name Records

While some have argued that the US has successfully diffused its security norms into the EU context, such as with EU-US agreements on Passenger Name Records (PNR) and Society for Worldwide Interbank Financial Telecommunication (SWIFT), this leaves an incomplete understanding of how they are received and transferred around the EU. After all, the EU is made up of twenty-eight member states and numerous other actors, and not all EU actors immediately accept US norms, if they ever do. Germany and the UK are two major member states that were historically at almost opposite ends of the spectrum when it came to measures requiring personal data, with the UK pushing for greater EU counter-terrorism co-operation and Germany more sceptical and wanting to ensure strong data protection safeguards. However, we argue that there has been a change in this situation: the UK and German positions are now converging on EU-PNR, which is currently being pushed through with some urgency in Brussels. In this paper, we explore how, on the one hand, the UK has striven to diffuse its norms when it comes to counter-terrorism and surveillance across the EU, while at the same time looking into how those member states further away from British norms have reacted and adapted to such attempts. We argue that the UK has been a very effective ‘norm-maker’, but that we should not perceive German policy-makers as mere ‘norm-takers’ but also as entrepreneurs willing to Europeanise domestic policies for their own political purposes.