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...