For example, in the UK, there's a CCTV on every corner, but photographing the police can get you up to 10 years in jail (http://www.msnbc.msn.com/id/29225389/) and harassment of photographers is common (http://youve-been-cromwelled.org/?p=1079 , http://www.guardian.co.uk/uk/2009/apr/16/police-delete-touri...). It seems Germany harasses photographers as well (http://www.toytowngermany.com/lofi/index.php/t3168.html).
I'm not a fan of the direction the US is going on this issue, either, but I don't think this is a case where Europe is doing better. On health-care and social safety nets, yes, but not on civil liberties, which was the subject at hand.
The problem is that the police on the ground have been whipped up into an anti-terror frenzy - and are largely thugs in any case - and there's a disturbing number of them just ignoring these instructions.
After the lack of prosecution over Ian Tomlinson's death, there's a strong feeling in the country that Something Needs To Be Done about the police. It's fine for them to club annoying hippies protesting about something or other, but the 'ordinary' people are starting to feel worried now and that won't end well.
As a non-European, based strictly on coverage I've seen as part of the photographic community, it seems that Britain's surveillance-happy tendencies are not nearly so strongly replicated through the rest of Europe.
The freedom situation in Britain has gotten so bad that I'm not sure that Brits have a leg to stand on when criticizing the US for its increasing lack of freedoms, the over-reaching arms of the law.
That being said, Americans have nothing to be proud of when it comes to these sorts of laws - they are a clear encroachment on your freedoms, and a clear example of the exact sort of power abuse that the Founding Fathers specifically forewarned of, and sought to prevent. It's so textbook as to be galling, yet the courts' support of them is just depressing.
In the UK if any action is causing distress to someone I think the police are allowed to stop you doing it (based on a naive reading). There are some pretty general laws on our statute books.
But it’s certainly true that the police can majorly inconvenience you. They can take your camera away and even though they have to give it back to you and are not allowed to delete anything that they can do that at all does suck. At least they cannot fine you or worse.
The most annoying thing is that many in the police seem to be unaware about the law. (They strangely never seem to have that problem when a law gives them more power.) They will lecture you on and on about personal rights even if those are irrelevant as long as you don’t plan to make the photos public. (And even if you, say, documented police brutality a newspaper could print the photo no problem, they would just have to pixelate faces.)
They might even not be allowed to look at your photos without a court order (since looking at your photos is a search – I’m not sure about that one).
They can only keep your camera around as long as they plan on using it as evidence – meaning that if there is no investigation or as soon as the investigation ends or after the court is finished with the case they have to give it back to you (unchanged if the court doesn’t rule otherwise – which it won’t).
The good news is that the police in Germany cannot make you pay a fine or get you into prison for taking photos of them. The bad news is that they can inconvenience you by temporarily taking away your camera. Which they can do but as soon as they delete so much as one photo you should defend yourself and sue.