(1) In all cases of major terrorist attack in the last 15 years the
    attackers have been known to the intelligence
    agencies. Furthermore adding more data just adds more noise. Why,
    then do we need mass interception warrants?

(2) Depending on the specific retention requirements, it is likely to
    require DPI. It's expensive. Also, as a service provider, it's
    none of my business what's in my customer's packets. They pay me
    to send them where they're supposed to go. Looking at them more
    than is required to debug network problems is unethical. I don't
    have any DPI kit, and I don't want any. I can mirror a port and
    run tcpdump if I need to.

(3) The definition of telecommunications service is so vague that it
    can catch anything from community organisations to GCHQ. Just who
    is meant to be subject to this law?

(4) There are numerous gags and coersions. My favourite one is how, if
    you are a (vaguely defined) telecommunications operator, and any one
    of dozens of officials think you don't have some data but can get
    it, they can ask you to get it for them in whatever way, and you
    have a duty to do it. Without a warrant. And jail if you blab.

(5) The mass surveillance capabilities aren't meant to be used in the
    UK, but it appears to be possible to acquire data from the entity
    doing that, again without a warrant.

(6) If you are accused of some crime and the evidence involves
    interception, it is not allowed to even refer to this in court --
    the provenance is therefore unquestionable. But no matter, this
    will never happen because only evidence acquired without a warrant
    from that retained by service providers will be used in court. The
    interception will just let them know what to ask for.

(7) The section on forcing companies to remove "protective measures"
    is either a fantasy, or a recipe to kill the UK tech industry. Or
    both. Nobody sane who expects people to trust their software would
    touch the UK if this becomes law. And any semi-competent criminal
    will very quickly figure out what safe end to end encryption
    software to use.

There's lots more. But to summarise, the law is buggy, even if it
weren't it wouldn't work and it would be very expensive both in terms
of operational cost and social cost.

-w

--
William Waites <[email protected]>  |  School of Informatics
   https://tardis.ed.ac.uk/~wwaites/      | University of Edinburgh
         https://hubs.net.uk/             |      HUBS AS60241

The University of Edinburgh is a charitable body, registered in
Scotland, with registration number SC005336.

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