When you have to make your living on privacy, you find out quickly who has money for it. Three years ago, the top answer was not corporations based in Canada, Latin America, Europe or Australia. While these regions preceded the U.S. in adopting comprehensive data-protection legislation and had enough budget to support a handful of local privacy practices, the number of corporate privacy executives and their budgetary authority always paled in comparison to their American counterparts.

But this year was different. I noted a significant increase in the level of European participation in the survey, matching the total for the U.S. Midwest region. Of the Europeans, nearly all were votes by and for U.K.-based firms.

What could be driving this change? A simple explanation could be language and culture. The survey was executed in English, and non-Anglo CPOs could be hesitant about taking an American survey.

A second factor also could be at play. One need look no further than the heightened enforcement and budgetary powers of U.K. Information Commissioner Richard Thomas, who has been charged by the prime minister to put a stop to the spate of data breaches occurring in the U.K.

"The stakes for privacy regulation in the U.K. are currently pretty high," said Eduardo Ustaran, a partner at London-based Field Fisher Waterhouse.