LSE Law Department Briefings on the Investigatory Powers Bill - Comparing Surveillance Powers: UK, US and France

Abstract:     

Both France and the US operate an extensive signals intelligence network, not unlike the UK’s, and both have experienced recent terrorist activity and remain likely targets for terrorist activity in the future, like the UK. At the same time, the US and France have a divergent approach to the legal framework for surveillance powers. The US is taking steps to reduce the legal authority of Federal bodies, including national security bodies, to intercept and retain communications data and content. France, on the other hand, has recently substantially extended authorisation and powers for interception and retention of data. In institutional terms, the United States operates a judicial authorisation process while France operates a political authorisation process, which is not unlike the double lock process proposed in the Investigatory Powers Bill.

Number of Pages in PDF File: 4

Keywords: IP Bill, investigatory powers, surveillance, terrorism, Freedom Act, CNCTR