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Yosi Many thanks for taking the trouble to think these issues through. There is however still an issues in my mind to be resolved. Yes, I agree that the 'handshake' is part of the contractual process' and is probably public domain.Yes, using sniffer software to look into the data subject's PC settings/logs appears to be an obvious breach of their rights. But what about a record of the browser's interests based on pages clicked or items purchased, that is then either "processed" internally or sold on to a third party. My feeling is that you would have to get informed consent to do this. Much is now being made of collaboration filtering, whereby I can predict the desires of a browser and direct my marketing to him/her based on the habits/purchases of completely different data subjects. This information is valuable and transferable. Dangerous?! Duncan S Smith