The advent of internet as a means of conducting trade has created
new challenges. It is not the first time that technology challenges
the efficiency of the current legal framework but the extent of the
threat to privacy renders a new approach imperative. In the light
of this realisation the different approaches towards data
protection in the EU and US are thoroughly analysed. The divergence
in the approach is flowing from different historical developments
and experiences and hence different legal traditions. The adoption
of the EU Directive on Data Protection has been the milestone which
reset the debate on a wholly different basis. It revealed the
cultural and legal differences between the two sides of the
Atlantic and underlined the difficulties in agreeing upon a common
solution. The paper focuses on the analysis of the relevant
historical and legal framework in the EU and US and concludes with
certain proposals of legal and technological nature to deal with
the problem. Its central thesis is that the challenges that
internet poses on privacy should be dealt within the context of
Europes established legal and humanistic traditions.
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