Consumer Protection and Global Trade in the DigitalEnvironment

The advent of internet as a means of conducting trade hascreated new challenges. It is not the first time that technology challenges theefficiency of the current legal framework but the extent of the threat to privacy renders a new approach imperative. In the light of this realisationthe different approaches towards data protection in the EU and US are thoroughlyanalysed. The divergence in the approach is flowing from different historicaldevelopments and experiences and hence different legal traditions. The adoption ofthe EU Directive on Data Protection has been the milestone which reset the debate ona wholly different basis. It revealed the cultural and legal differences between the twosides of the Atlantic and underlined the difficulties in agreeing upon a commonsolution. The paper focuses on the analysis of the relevant historical and legalframework in the EU and US and concludes with certain proposals of legal andtechnological nature to deal with the problem. Its central thesis is that the challengesthat internet poses on privacy should be dealt within the context of Europe'sestablished legal and humanistic traditions.