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French guy here. This article only speak about employees in american company getting fired about some data shared on the web. But I would be curious to know what happened to people who faced the same situation working in continental european companies. It would be surprising if people would lost their jobs so easily. Either because I think it's culturally better accepted for private people (I mean not public figures) to have unappropriate expressions publicly, plus the law don't allow companies (at least in France) to fire someone on a basis of only one unappropriate expression not even targeting another employee or customer of this company.


>Either because I think it's culturally better accepted for private people (I mean not public figures) to have unappropriate expressions publicly

Based on my (admittedly very limited) experience with French culture, this is definitely the most important difference.

America has become extremely politically correct. People in France are much more relaxed about saying things Americans might construe as offensive. In particular, Americans tend to be much more wary of speaking about perceived victim groups (certain racial groups, homosexuals, etc.).


"Based on my (admittedly very limited) experience with French culture, this is definitely the most important difference."

Unless they are saying something conceivably pro-Nazi?


In fact, saying something pro-Nazi is criminal in many EU countries.

In France, there are fewer social proscriptions on speech.

In the US, there are fewer legal proscriptions on speech.


Yes, you can even go to jail for that in lot of EU countries.


Well, in Europe the tradition of mobbing is a serious problem, and its definitely something that occurs on a regular basis in the real world, and not just on the Internet. In Germany, people have been fired for instigating the mob - not necessarily for saying things that offend others, but rather for rabble-rousing and trying to get the pitchfork brigade riled up.

I think Europe has a keener sense of the history of this activity, because the artifacts of prior historical mobbing are abundant. You only have to take a walk through Prague, Budapest, Berlin to see just how this is reflected in European sensibilities - whereas in the US, its a less overt historical fact. Americans are very loud about things, Europeans often very reserved and conservative, but there is fundamentally no difference between the cultures: both are capable of succumbing to cannibalistic, collective-reactive urges. I witnessed this factor countless times in my experience living in the US (I'm not American), most severely during the Rodney King riots. People form a kind of super-being in a mob, a near God-like entity, which can perform powerful acts - go to the moon, solve humanitarian crises, and so on. But it can also turn vicious and heinous as well, and there seems to be some sort of scale upon which the tone of activity can be plotted. I don't think there is a difference in scales for European versus American societies; just that the fact of observation of the energy of the mob is louder in some cultures that have evolved to profit from that loudness - America, in this case. Celebrity/Entertainment culture being what it is in the US, I think its just a brighter shade of pale than, for example, the French may be used to - but its the same basic color.


My english is not perfect and reading you answer I thing I was misunderstood.

This kind of mobbing and over reaction do happens in France as well and I don't deny that. Recently 3 millions get down the street because 18 peoples has been killed. So I acknowledge that over-reaction is not just an american thing. It's more on the employer side that I'm surprised. If an employer is not stupid why would he fire someone on these bases?


I believe its because more often than not, the employer is profiting direction from the mobs own ignorance of itself. A classic case is where employees are not allowed to discuss their wages, as this of course allows the 'owner' of the organization to make bargains and deals, and so on. So the function of leadership, expressed as control over the crowd, has its own degrees of +/-'ve reality. In an open group, where everyone knows everything, its quite difficult to rile people up and get them to pick on an individual member; the dark line that forms around mysteries, lies, deceit and intrigue, is precisely the abyss into which any individual may fall. And it is always 'others' who push them into it.


> In Germany, people have been fired for instigating the mob - not necessarily for saying things that offend others, but rather for rabble-rousing and trying to get the pitchfork brigade riled up.

One of the reasons I love Germany and Germans. They like to solve the root problem rather than trying to pretend to.


> People form a kind of super-being in a mob, a near God-like entity, which can perform powerful acts - go to the moon, solve humanitarian crises, and so on.

I'd hardly call NASA or UNICEF a mob.


Maybe mob is one end of the spectrum, and "organized space-exploration organization" is the other end.


French guy here as well, and this was exactly my reaction. It seemed very exotic, this notion that an employer was allowed to fire you just because a bunch of people on the Internet have started disliking you in a vocal way because of something you said (as an individual, not reflecting your employer's opinion, not illegal).

This feels like the main issue here. Barring substantial improvements in everyone's maturity, you won't be able to prevent random people on the Internet from focusing on you for whatever reason. The actual individual actions that follow, however (the employer arbitrarily sacking you, people refusing you service, people harassing you, etc.) are what crosses the line, in my opinion.


You might not be fired, but you can be arrested for expressing an inappropriate opinion in France. See the string of recent arrests over comments people made about the Charlie Hebdo shootings.


Really? I'll be interested in sources then, because I've just never heard of such things in France. From what I know even well known public figures that has been sentenced about innapropriate expressions just had been fined (Le pen) or had their show cancelled in some cities (Dieudonné)


Sure thing.

France: Dieudonné sera jugé pour «apologie de terrorisme»

http://www.rfi.fr/france/20150114-france-dieudonne-sera-juge...

France arrests 54 for ‘defending terrorism’ after Charlie Hebdo attack

The Justice Ministry said that 54 people, including four minors, have been detained for defending or verbally threatening terrorism since the Charlie Hebdo attack. Several have already been convicted under special measures for immediate sentencing.

http://america.aljazeera.com/articles/2015/1/14/france-charl...

France arrests 54 in hate speech crackdown, boosts anti-ISIS support

http://www.cbsnews.com/news/french-lawmakers-approve-more-ai...

French Comedian Dieudonne Goes On Trial For 'Defending Terrorism'

http://www.npr.org/blogs/thetwo-way/2015/02/04/383767811/fre...

Why French Law Treats Dieudonné and Charlie Hebdo Differently

http://www.newyorker.com/news/news-desk/french-law-treats-di...


All right, random people has been arrested and taken in custody during 48 hours after the Charlie things. I was actually meaning people jailed for months and lost their jobs and suffer all the dramatic effects of prison.


Well, according to the Al Jazeera article, some have already been convicted and sentenced.


I don't know about people being arrested for comments about Charlie Hebdo, but people have been fined and imprisoned for statements about the Holocaust: http://en.wikipedia.org/wiki/Laws_against_Holocaust_denial#P...


Thank you very much. The english version of wikipedia state that Roger Garaudy and Jean Plantin has been jailed whereas the french version of their wikipedia pages state they hasn't been. So it would be good to have reliable sources.

BUT you actually pointed me to a guy that has been an exception to both of my statements. Vincent Reynouard has been jailed for revisionism after having published a book and a video tape about the massacre of small village in south of France during War World 2 https://en.wikipedia.org/wiki/Oradour-sur-Glane

And even before that he lost his job as a teacher because he had some revisionist document on its work computer http://www.liberation.fr/france/1997/04/23/le-prof-revisionn...

So he is really the exception which proves the rule.


you're wrong, this happened in France too, and it happened a lot last year : http://rue89.nouvelobs.com/2014/01/02/quenelle-nabil-perd-em...

just one example...


Ok but when I wrote fired, I was thinking about permanent position (CDI). The article state that he has been forced to quit his job rather than being fired, which is not really clear. His position may has just been a seasonal one as the place he was working in is apparently opened during summer only.


Another nice thing about France, at least it used to be that way, was that office romances were not frowned upon. You could actually have playful innuendo and it was just ordinary. I'm not saying offensiveness was allowed, no, just that people could be people, comment on looks, dress, etc. and not have it be seen as verbal sadism.


This is interesting. I wonder where the line is drawn, though (surely there are some ways to get fired by saying something in Europe).

I believe that it will soon become necessary for some sort of online bill of rights which protects one's identit(y,ies) and privacy.


I'll reply only in regards of french law here but be aware I'm no lawyer. The basis is the following. You can fire someone for repeatedly public attacks targeting another employee, or a client. Then if the fired employee thing you're wrong then a kind of court dedicated to work legislation will decide if you have enough element to have him fired or not.


I read of a case here in Germany where workers refused to work with a known pedophile, and the company really struggled to get rid of him. It went through several trials where they weren't allowed to fire him.




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