Case studies: UK, Russia and EU increased electronic surveillance


Monitors show imagery from security cameras seen at the Lower Manhattan Security Initiative on April 23, 2013 in New York City. At the counter-terrorism center, police and private security personel monitor more than 4,000 surveillance cameras and license plate readers mounted around the Financial District and surrounding parts of Lower Manhattan. Designed to identify potential threats it is modeled after London's "Ring of Steel" system.


John Moore

Nearly everyone has heard the story by now.

The US National Security Agency has been keeping tabs on people’s phone records and internet browsing, including audio and video chats, photographs, emails, documents and connection logs.

There has been little surprise, but lots of outrage.

Why is the government doing this? To protect you, of course.

President Barack Obama defended the government’s surveillance program Friday, saying, “You could complain about Big Brother and how this is a potential program run amok, but when you actually look at the details, I think we strike the right balance.”

He warned, “You can’t have 100 percent security and also then have 100 percent privacy and zero inconvenience.”

Explaining that his administration had increased oversight over the programs, Obama said, “But my assessment and my team’s assessment was that they help us prevent terrorist attacks.”

Democratic Sen. Dianne Feinstein, who chairs the Senate Intelligence Committee, said Thursday, “It’s called protecting America.”

The House Intelligence Committee’s chairman, Republican Rep. Mike Rogers, echoed the sentiment Thursday, “Within the last few years, this program was used to stop a terrorist attack in the United States.”

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This is hardly the first time the government has compromised citizens' privacy and civil liberties for the sake of national security.

However, the American public’s attitude toward losing civil liberties has changed. A CNN/Time/ORC International survey released May 1, in the wake of the Boston Marathon bombing, found that while 40 percent of those asked were willing to give up some civil liberties to curb terrorism, 49 percent were not willing.

In 1995, after the deadly Oklahoma City bombing, 57 percent of those polled said they were willing to give up some civil liberties to combat terrorism.

In the wake of 9/11, 54 percent of Americans favored expanded government monitoring of phones and email, said CNN Polling Director Keating Holland. Now, only 38 percent favor such monitoring.

GlobalPost took a look at other countries that have had to weigh national security versus civil liberties:

United Kingdom

One of the icons of modern Britain is the ubiquitous CCTV camera on every street corner. The UK started on its path to installing 4 million surveillance camera because of attacks by the Irish Republican Army in the '70s and '80s.

A ‘Ring of Steel’ was built in London’s financial district after bombings in the early 1990s.

GlobalPost video: UK living under the CCTV gaze

However, RIPA, as the Regulation of Investigatory Powers Act is known, was passed in 2000 to regulate how government could carry out surveillance and intercept communications.

As the UK’s government website explains it, the law makes sure that when the authorities need to obtain private information including phone calls, emails, letters, surveillance or electronic data, “they do it in a way that is necessary, proportionate, and compatible with human rights.”


Russia’s System of Operative Search Measures — SORM for short — has existed for more than two decades, but it was recently upgraded to include not just landlines, but also mobile networks.

SORM’s foundations were developed by a KGB research institute in the 1980s, but SORM-2 now intercepts internet traffic, while SORM-3 gathers intel from all communication platforms and stores it for up to three years.

An agent from Russia’s security agency, FSB, is required to obtain a warrant for eavesdropping, but he doesn’t have to show it to anyone.

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Since Nov. 1, 2012, Moscow has also been able to blacklist websites thanks to the Single Register.

Foreign Policy magazine puts it this way: “The introduction of national internet filtering was one of the measures the Kremlin adopted in response to the Arab Spring as well as the street protests that erupted following last year's controversial Russian presidential election. To the Kremlin and the security services, these events served as proof that social networks were another tool created by the United States to topple regimes in the countries where the opposition is too weak to mobilize protests.”

European Union

In 2006, the legislative body of the European Union passed the Data Retention Directive, which required all internet providers, telecom firms and phone companies to store traffic and location data for six months.

The point of the legislation was to aid anti-terror investigations. As the EU explains, the data is used by "law enforcement authorities for the purposes of investigating, detecting and prosecuting serious crime and terrorism."

However, the directive was met with resistance in many member states of the EU, including Sweden, which was ordered to pay 3 million euros for delaying transposing the directive into national law. Sweden has since adopted the directive.

Germany and Belgium have only transposed the law partially into their national law books.

The European Data Protection Supervisor said in 2011 that the directive “failed to meet its main purpose.”

Though there is no timeline, there are ongoing efforts to reform the directive's framework.


Despite being fined for delaying the EU’s directive on data retention, Sweden passed its own set of laws which would allow authorities to scan emails, faxes and phone calls in 2008. Much like the NSA promised before the recent revelations, Sweden’s government insisted that it would leave out domestic communication.

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