Since the invention of radio, intelligence-gathering organizations have been developing and using eavesdropping techniques to intercept and review wireless communications. Initially, these capabilities were solely used to spy on hostile nations, and particularly for military purposes. Human operators had to manually review each transmission, and cryptanalysts pored over military ciphers in an attempt to decode important messages. As wireless communication has become an integral part of commercial and individual existence, and potential threats to security are increasingly found in peacetime and on home ground, the scope of this intelligence gathering has likewise broadened. One of the most controversial eavesdropping systems in existence is a classified project known as ‘Echelon.’ Its use of computer hardware and software to filter communications from all over the world brings up many ethical issues related to the impact of computers on privacy.

Overview of Echelon

Most of the evidence for Echelon is circumstantial, though a few facts have been established. The participating organizations (notably the US Central Intelligence Agency and National Security Agency) have neither confirmed nor denied its existence. In lieu of a discussion of the ethical issues, a brief summary of the current knowledge follows.

How it Works

Echelon is the product of Cold War efforts to monitor wireless communications in the USSR. It traces its roots back to the clandestine UKUSA alliance, a communications intelligence agreement that dates back from around 1947. Member nations include the US, Great Britain, Canada, Australia, and New Zealand. It is now known that the system has been in existence for at least 20 years.[1] In the past, high frequency radio listening posts were also used to listen to radio communications. Currently, the system is composed of a series of eavesdropping satellites, ground listening stations, and supercomputers that intercept and sift through telecommunications satellite broadcasts. These broadcasts include faxes, phone calls, and web traffic- especially those dispatched over long distances.[2] The term Echelon has never actually been mentioned by officials, but is believed to represent the computer system that manages the data gathered by the network.[3] The computers are used to store and analyze text data for key words, and to review telephone conversations for unique ‘voiceprints’ or the phone numbers of persons under surveillance.[4] This makes it possible to filter an enormous amount of traffic, since human analysts review only relevant messages. The US National Security Agency (NSA) is widely considered to be both the originator and head of the project, and likely owns and operates the major computer facilities for Echelon.

Original and Current Purpose

Initially, the system was intended to intercept and analyze all manner of communications from East Bloc countries. Emphasis was placed on messages with military, political, or economic information- in that order of importance. Even before the dissolution of the Soviet Union, intelligence services like the NSA were turning their eyes inward- toward potential troublemakers within friendly territory. While Echelon is still used to spy on former Soviet countries, it is now also used to listen in on the conversations of allies- possibly including UKUSA member nations. The system has been continually upgraded and expanded despite the disappearance of the original threat.[5]

What is Suspected?

Potential Capabilities

Though voiceprint and phone number matches on telephone calls are useful for identifying known suspects, it would clearly be more powerful for Echelon to be able to run a keyword search on all conversations, much as it does for faxes and e-mail. Speech recognition techniques make this possible, and have already seen extensive use in the private sector. There is some debate as to whether the NSA’s computers have the capability to use current techniques on the tremendous amount of phone traffic the system can pull in. Some suspect that they currently convert phone messages to plain text, allowing the same keyword searches to be conducted.[6] Either way, few doubt that if the NSA does not have this capability, it is working to acquire it. In addition to this, use of AI techniques such as natural language processing could allow the filters to not just do a simple keyword search, but to actually analyze the subject of written or spoken words. This would greatly increase the effectiveness of filters, and allow for faster and extended surveillance.

With a fleet of eavesdropping satellites estimated to number over a hundred, plus ground intercept stations (not all of which are in UKUSA member countries) Echelon is at least capable of conducting an unprecedented amount of domestic and corporate espionage.[7] It is also a matter of debate as to whether the system is being used for this purpose. In April 2000, NSA Director Gen. Michael Hayden was quoted saying, “I recognize that it is standard practice for some countries to use their intelligence services to conduct economic espionage, but that is not the policy or practice of the United States.”[8] At the same time, the CIA has admitted to using eavesdropping to verify that foreign companies are using unfair practices to acquire contracts. There is some evidence that this investigation includes monitoring of corporate activities that aren’t technically illegal.[9] Where does the intercepted information go?

Uses in the Past?

Since the NSA and other intelligence organizations have never even confirmed Echelon’s existence, it is unlikely they would confirm its use in specific cases. However, there are some documented instances where it is highly likely that the system was employed. The most notable of these were outlined in a lengthy European Parliament report on Echelon.[10]

1994- Regarding a contract for aircraft for Saudi Arabian national airlines ($6 billion). Interception of communications between the employer and Airbus revealed that bribery was taking place. McDonnell Douglas won the contract.

1994- Regarding a contract for satellite monitoring of the Amazon Basin ($1.4 billion). Interception of communications between the Brazilian Government and Thomson-Alcatel showed that bribes were being offered. The contract was awarded to Raytheon.

Some believe that other companies, such as Boeing and Hughes Network Systems, have received intelligence information from Echelon. In these cases, it was likely not a direct transfer from the NSA to the companies, but rather a ‘roundabout’ approach through a government organization such as the Commerce Department’s Advocacy Center.[11]

Legal Discussion

For the sake of further discussion, it is important to review relevant legislation regarding a system like Echelon. Since the greatest uproar to date regarding the secret system has come from Europe, and Echelon is considered to be the domain of US intelligence agencies, this discussion will focus on American and European Union laws.

Applicable Laws in the US

Privacy Act of 1974- Establishes guidelines for data storage and computer matching (both of which are used by Echelon), including use by federal agencies. Deals specifically with records maintained on individuals.[12]

Foreign Intelligence Surveillance Act (1974)- Establishes rules for the use of surveillance systems, especially wiretapping and eavesdropping by federal agencies. Authorizes use when it pertains to ‘foreign intelligence’ regarding a ‘foreign power’ or an agent thereof. The definition of a foreign power includes a "foreign-based political organization, not substantially composed of United States persons” or an entity that is controlled or directed by a foreign government. The term ‘substantially’ is not defined.[13]

Executive Order 12333 (1981)- Outlines the NSA as the sole collector of signals intelligence, under the direction of the CIA. Prohibits electronic surveillance conducted inside the US by the CIA. Surveillance done by the FBI in the US must involve foreign intelligence or a lawful investigation.[14]

United States Code: Title 18, Chapter 119, Section 2511- Prohibits interception of wire, oral, or electronic communications by anyone in the United States and US territories. Exceptions include certain cases (emergency services, FCC radio monitoring, things broadcasted to the public) and those cases described in FISA, with a court order or authorization from persons with the power to bypass the warrant (e.g. the Attorney General).[15]

USA Patriot Act (2001)- Enhances powers granted by FISA. Allows disclosures of electronic information for emergency purposes. Reduces the difficulty of acquiring warrants for electronic surveillance, and introduces or expands situations in which warrants are not necessary. Investigations involving terrorism or foreign intelligence are granted increased scope of surveillance.[16], [17]

There is one key thing to note in US law- what protections they offer only cover citizens and legal residents of the US, and oftentimes only if the intelligence is gathered on US territory. As we have seen, Echelon neatly sidesteps the territory issue via the UKUSA alliance, and there are quite a few loopholes in the laws themselves (most notably in FISA and the Patriot Act). Additionally, the secret nature of the system and the controlling agencies make oversight difficult at best.

Comparison to the European Union

The European Union has many stringent privacy laws, most notable of which is the Data Protection Directive (DPD). Among other things, these regulations only allow collection of data for specific purposes and with a court order. Certain ‘special categories’ of data (e.g. political views, personal health information, religious beliefs) cannot be processed except under the following conditions: [18], [19]

· With explicit consent by the person.

· For the purposes of fulfilling some national employment laws.

· For the protection of vital interests of the subject when they can’t legally give consent.

· By a non-profit organization with whom the person has regular contact (but only by them).

· If the data is made public by the subject themselves, or is necessary for legal claims.

In any case, the persons involved must be notified about data collection or processing and have access to the data, and the data can’t be maintained ‘longer than is necessary.’ There are, however, articles allowing for exemptions for government data gathering and use for criminal or security purposes. Defense, national security, public security, and protection of “an important economic or financial interest of a Member State or of the European Union” are included in these exemptions.[20]

Despite the exemptions, it is clear that the European Parliament has a very different perspective on personal privacy and privacy violations than the US Government. The DPD requires strong oversight in every situation- including the exemptions mentioned above. Especially following the 9/11 terror attacks, US law has been trending toward less oversight and more leeway for security measures- including eavesdropping systems like Echelon. In Europe, the European Parliament and various national governments must guarantee significant privacy to their citizens, whereas in the US this privacy is expected, but not necessarily guaranteed. There is little oversight for secret agencies like the NSA, no equivalent for the DPD in US law, and most US legislation regarding electronic privacy is dated.[21]

Justifications For and Against

Security

One of the necessary things for a reasonable standard of living is protection from physical harm. It can be shown that people will willingly sacrifice some autonomy for security from potential enemies, and the rise of government in human society is largely attributed to a need for protection against threats both at home and abroad. Echelon is clearly a powerful tool in times of open conflict, and has been used to gather intelligence during the Gulf War, Kosovo conflict, Afghanistan, and the War in Iraq. Additionally, it is an equally powerful tool in times of peace to guard against terrorist acts. In April of 2004, nine terrorist suspects were arrested in England following an NSA interception of communications between the UK and Pakistan.[22] It is almost a certainty that Echelon was used in this case. With the new world situation where terrorists strike on home soil without declarations of war, and terror suspects may include common citizens as well as foreign infiltrators, it is easy to see the value of a powerful eavesdropping system for national security purposes. At the very least, the existence of a system like Echelon would deter or deny several convenient and effective means of communication between terrorists, thus hampering the coordination of devastating attacks.

It is widely known that terrorists finance their efforts at least in part through front companies, special interest organizations, and charities. Thus, using Echelon to intercept business and perhaps even political communications can be useful in cutting off this crucial terrorist resource. It should also be noted that non-UKUSA member countries would benefit (and likely have benefited) from intelligence gleaned by the system.

Privacy

Author Sara Baase describes privacy as “the ‘computer issue’ that worries people most.”[23] It should be no surprise, then, that the main arguments against Echelon all relate to personal privacy and the related concept of civil liberty. There is a balance that must be struck between security and privacy, since they tend to conflict; more government monitoring and surveillance certainly helps deter crime, but this also deters freedom of speech and individual expression.

What is the impact of Echelon on privacy? Ruth Gavison defines privacy as “a limitation of others’ access to an individual… a loss of privacy occurs as others obtain information about an individual, pay attention to him, or gain access to him.”[24] She also notes that the value of privacy includes “the promotion of liberty, autonomy, selfhood, and human relations, and furthering the existence of a free society.”[25] Does Echelon violate the privacy of individuals, and if so, how badly? Clearly, eavesdropping on private conversations results in the system obtaining information about people and paying attention to them. However, so long as a human isn’t reviewing the conversation, is this a breach of privacy? Does intercepting, temporarily storing, and filtering messages impact those values of privacy mentioned above? Does intercepting corporate communications constitute a breach of personal privacy, even if its goal is targeted at verifying a company’s fair practices, and not the business of any particular person? Does the lack of any ‘opt out’ for Echelon make it an unreasonable and inescapable intrusion into normal, lawful people’s lives? Whatever the answers to these questions, all of which are highly opinionated, there is no doubt that the system has some sort of negative impact on personal privacy.

Ethical Issues

As is well known, filtering software is far from perfect. This is especially the case when the technology is limited to a simple keyword search, as Echelon is purported to be now. Intercepting satellite transmissions allows it to sift through many kinds of communications from all over the world. Therefore, it is likely that analysts occasionally review messages with no relation to terrorism or foreign intelligence. Even if the software was perfect, the mere fact that a computer system is storing and inspecting intercepted communications raises significant ethical issues.

Deontological Perspective

Arguments for and Against

Any government has a duty to protect its people from attacks by a foreign power. This is generally agreed to hold even if the people have little or no say in government. In order to carry out this duty, it is oftentimes necessary for surveillance to be conducted on other nations. This is considered a normal matter of business even among allied nations, and signals intelligence is just one facet of surveillance. The points of debate arise when surveillance is conducted on civilians and other non-combatant entities, either at home or in allied countries. These issues hold whether the surveillance is done for the civilian’s own protection or for the purpose of protecting the government itself. Additionally, it is commonly held that a government’s duty includes protecting against foreign espionage (also known as ‘countersurveillance’). Clearly, then, there is a problem when considering a system like Echelon, which is run by an alliance of nations and intercepts communications from many other nations.

In conceiving and running this project, the National Security Agency is ostensibly executing the duty of the US Government to protect US citizens from potential enemies. Other members of the UKUSA alliance are likewise cooperating to gain information to help secure their country. Questions arise when one considers the definition of national security. Does it include more than defending against hostile attacks, but also protecting national interests? Is it the government’s duty to verify that international economic activities- not necessarily involving hostile actions- are in line with international law, as was the case in the two 1994 situations described above? Is stiff competition and unsavory (but not illegal) corporate maneuvering an attack on national interests, and therefore deserving of government espionage and defensive responses? Note that both of the known cases involved important US defense contractors. Does this justify eavesdropping for national security purposes? From a duty-based perspective, it is not clear whether defending national interests justifies the use of eavesdropping on the sweeping scale Echelon employs.

Do governments also have a duty to protect the privacy of their citizens? Many nations have laws regarding privacy, usually affording some sort of protection from the government itself. In the case of the existence of such law, the government is obligated to enforce it and to enact self-regulation or prohibition against the use of eavesdropping technology on their citizens. What about a government’s duty in countersurveillance, when the eavesdropping is being done by a foreign power? It is likely that a government would object to a foreign entity conducting espionage, if only for the fact that the government’s own communications might be intercepted. Supposing they do not, do they still maintain an obligation to protect their people from this form of surveillance? If the information gathered could lead to harm for the people under their protection, the answer is yes. However, if it causes no apparent harm (as would be the case in a message that gets through the filters, but has no intelligence value and is immediately discarded) or only targets criminals and other miscreants, it is not so clear what the government’s position should be.

Ethical Analysis

It is not immediately clear if Echelon’s use in the past, and current and future purpose are supported from this perspective. This is largely due to a lack of knowledge regarding exactly how the filtering system works- in particular, which key words are flagged and for what reason. There is little question that if the system is used to track down terrorists, it is justified. However, the other potential uses for Echelon may not be justified. More information regarding the system’s use to promote US interests and conduct foreign intelligence is needed before a course of action can be suggested.

Utilitarian Perspective

Arguments for and Against

Would people be better off with or without Echelon? There are two opposing views under the utilitarian perspective, which follow directly from the security vs. privacy debate. Privacy is definitely something that people attribute value to. Many people have information that they would prefer to remain undisclosed, either due to the potential for embarrassment or to retain a competitive edge. However, as James Rachels pointed out, people still value privacy when they have nothing to hide, or are otherwise engaging in activity that is perfectly normal.[26] For example, I may call my cousin in Malaysia (a largely Islamic nation) for a routine chat in which we discuss the US military and foreign policy. Along the way, the message is transmitted to and from a satellite, at which point an NSA listening post picks it up. Echelon notes the mention of ‘bombs’ and ‘president’ and snaps it up for analysis. An NSA analyst somewhere listens to a recording or reads a transcript, sees nothing unusual, and dumps it (or not?). The call content was mundane and nothing we would care to keep secret, but if either of us realized that our call was being intercepted and reviewed, we would be displeased. We’d likely be far more careful what we say in future conversations, and this would hamper our ability to speak freely as family. As the European Parliament report noted, Echelon isn’t exactly Big Brother in an NSA mainframe- the amount of traffic sent through satellites, though massive, is still only a fraction of total communications.[27] The danger is that, if unchallenged, Echelon sets a precedent for more sweeping surveillance measures. Additionally, the shift from wired to wireless communications is well underway, and the European Parliament observation might no longer hold in five to ten years. It’s hard to imagine a lower level of happiness than what would exist in an Orwellian world where everything you say is recorded and reviewed, and it’s getting increasingly more difficult to communicate without transmitting something through open air.

At the same time, there is no question that corporate fraud, terror attacks, and crime have a negative impact on utility. When there is a lack of security, people live in fear of their lives and livelihood. Should any of these nefarious dealings actually happen, it damages or destroys both, and also reinforces the fear for those not directly affected. Echelon has shown its worth in preventing fraud and at least deterring acts of terror, and could (if it isn’t already) be used to locate and arrest non-terrorist criminals. There is little doubt that the result of using the system for these purposes is beneficial to utility.

Ethical Analysis

The deployment of Echelon is justified by a utilitarian standpoint, but only to a certain extent. There is a certain point where the benefits it provides in increased security are outweighed by the negative impact of surveillance on undeserving individuals. Advances in the software used to filter results, additional oversight, and new interception technologies may allow Echelon to expand without crossing this line. Additionally, if some non-critical information about the system is released to the public, it could assuage existing concerns about invasions of privacy. Particularly, there needs to be substance behind the NSA and CIA claims that eavesdropping is not used for industrial espionage, that the communications of normal individuals are not purposely reviewed or stored, and that adequate oversight is in place and functioning.

Natural Rights Perspective

Arguments for and Against

Do people have a natural right to privacy? Most would say yes, but only to a certain point. In a society one cannot, for example, claim absolute privacy as a right, since it is quite impossible.[28] Gavison argues, however, that some measure of privacy is necessary for both individual freedom and the protection of freedom.[29] Liberty is considered to be a natural right, so it follows that individuals have a natural right to privacy. The question, then, is whether Echelon violates the natural right to privacy, to the extent that this right is granted.

As is known by most savvy web users, anything sent by e-mail will be stored in any number of computer records, and can be picked up and read by anyone with access to those records. Echelon is not the only system built to intercept this particular medium of communication, and likely has a smaller scope in this regard than most others (e.g. the FBI’s Carnivore). Where Echelon presents novel issues is in its analysis of intercepted faxes and phone calls- a capability only otherwise possible with wiretaps, which are far more difficult to set up and often require a warrant. Is this a violation of the right to privacy when the subjects of the surveillance haven’t done any wrong, and don’t plan to do any? What about individuals or companies that are under suspicion for crimes? What about suspected terrorists or criminals? It would seem there are differing answers in each of these situations, but Echelon has likely processed examples from each of them.

One must also consider the capability for Echelon to protect other natural rights, most notably the rights to life and property. Unfortunately, there will always be some individuals who choose to deprive others of these rights. Clearly, if the system is successful in stopping or deterring terror attacks, it is benefiting those that would have been harmed or killed had the attacks succeeded. Additionally, if it is useful in preventing corporate fraud, one can argue that it is protecting the property of the defrauded party. It can be further argued that these rights supersede the right to privacy since most would not mind trading a bit of privacy for life and limb- even if it’s not their own that is at risk. While there may be intelligence-gathering alternatives to Echelon, such as placing closed circuit cameras and listening devices in public areas, Echelon may be the only way some incriminating communications will be uncovered. If it is used as a tool to track and punish those who would deprive others of ‘important’ natural rights, can we live with the possibility that Echelon may slightly violate our right to privacy?

Ethical Analysis

In a manner similar to that of the utilitarian standpoint, Echelon is justified from a Natural Rights perspective up to a certain point. The system can be used to safeguard the lives and property of parties under its protection (people of the UKUSA nations and possibly some allies), but also- if taken too far- can violate the rights of these and other people.

Thesis and Defense

Personal Position

At the present, if the assurances by the organizations in charge are to be believed, Echelon’s use is ethically justifiable.

Defense

Echelon, though a product of the Cold War, has shown that it is adaptable to current security situations. It is an unfortunate fact that advances in wireless communications, while providing numerous good uses and conveniences, also facilitate the coordination of fraud and terrorist attacks. The deployment of an intercept and analysis system like Echelon acts as more than a means of capturing such criminals, but also as a strong deterrent from using the medium for these purposes. Despite concerns about the NSA targeting civilians or conducting industrial espionage with Echelon, there is as yet no evidence that such activities have occurred. On the other hand, there is evidence that the system has been used to locate and eliminate terrorists. Additionally, there is little motivation for the NSA, CIA, or other UKUSA intelligence organizations to evaluate communications with no bearing on corporate fraud or national security.

The scope of Echelon, while large, is not exhaustive. While interception of satellite communications has a negative impact on privacy, filtering techniques ensure that nearly none of these transmissions are actually seen by human eyes, and even fewer are actually reported.[30] There also remain many means of communications (notably, anything sent via wire or cable) that are quite safe from its scrutiny. Additionally, the development and use of encryption in wireless communications presents an interesting option for privacy that could render the whole question of Echelon’s use a moot point.

There is some concern as to how Echelon stores the vast amount of information it collects, exactly how it filters communications, and who has access to the intelligence gleaned from it. Oversight and legislative measures are in place, but there is some debate as to whether these are adequate. Due to the project’s secret nature, even the experts can only offer possibilities in this regard. Pending further information on these matters, this argument is subject to change.

Conclusion

As it has in the past, Echelon is likely to change as technology improves and its mission profile changes. However, at the present, it is a useful a tool in the war against terror. Following the devastation of terrorist attacks in the last decade, any such tool should at least be given the benefit of a doubt. If evidence comes to light that Echelon has been misused, then steps should be taken to reduce or remove its capabilities. While there has always been a need for secrecy in intelligence gathering techniques, it would also help if the NSA and other participating organizations released some non-critical information about the system- particularly about how oversight is conducted. This could go a long way toward easing fears both in the US and overseas regarding Echelon’s capabilities.

References

[1]Cyber-rights.org, Interception Capabilities 2000, 2000, Cyber-rights.org, 8 May 2004, http://www.cyber-rights.org/interception/stoa/ic2kreport.htm#Summary

[2] Duncan Campbell, Inside Echelon, 2000, Heise Online, 10 May 2004, http://www.heise.de/tp/english/inhalt/te/6929/1.html

[3] Sara Baase, A Gift of Fire, Second Edition (Upper Saddle River, New Jersey: Prentice-Hall, 2003) 107.

[4] Patrick S. Poole, Echelon: America’s Secret Global Surveillance Network, 2000, Patrick S. Poole, 8 May 2004, http://fly.hiwaay.net/~pspoole/echelon.html

[5] Nicky Hager, Secret Power- New Zealand’s Role in the International Spy Network, 1996, Federation of American Scientists, 12 May 2004, http://www.fas.org/irp/eprint/sp/sp_c2.htm

[6] Patrick S. Poole, Echelon: America’s Secret Global Surveillance Network, 2000, Patrick S. Poole, 8 May 2004, http://fly.hiwaay.net/~pspoole/echelon.html

[7] Cyber-rights.org, Interception Capabilities 2000, 2000, Cyber-rights.org, 8 May 2004, http://www.cyber-rights.org/interception/stoa/ic2kreport.htm#Summary

[8] CNN.com NewsNet, High-tech Spy Satellites Not Targeting Americans, CIA, NSA Directors Say, 2000, CNN.com, 8 May 2004, http://www.cnn.com/2000/US/04/12/spies.speak/

[9] Robert Windrem, U.S. Steps Up Commercial Spying, 2004, MSNBC News, 10 May 2004, http://msnbc.com/news/403435.asp?cp1=1

[10] European Parliament, Draft Report: Temporary Committee on the ECHELON Interception System (pgs. 88-92), 2004, The European Parliament, 10 May 2004, http://www.europarl.eu.int/tempcom/echelon/pdf/prechelon_en.pdf

[11] Robert Windrem, U.S. Steps Up Commercial Spying, 2004, MSNBC News, 10 May 2004, http://msnbc.com/news/403435.asp?cp1=1

[12] US Department of Justice, The Privacy Act of 1974, 1974, US Department of Justice, 14 May 2004, http://www.usdoj.gov/foia/privstat.htm

[13] Lee Tien, Foreign Intelligence Surveillance Act Frequently Asked Questions (and Answers), 2001, Electronic Frontier Foundation, 12 May 2004, http://www.eff.org/Privacy/Surveillance/Terrorism/fisa_faq.html

[14] US Government, Executive Order 12333, 1981, Granite Island Group, 14 May 2004, http://www.tscm.com/EO12333.html

[15] US Government, United States Code, N/A, Cornell Law School Legal Information Institute, 16 May 2004, http://www4.law.cornell.edu/uscode/18/2511.html

[16] EFF, EFF Analysis of the Provisions of the USA Patriot Act, 2001, Electronic Frontier Foundation, 18 May 2004, http://www.eff.org/Privacy/Surveillance/Terrorism/20011031_eff_usa_patriot_analysis.html

[17] US Government, USA Patriot Act, 2001, Library of Congress, 18 May 2004, http://thomas.loc.gov/cgi-bin/bdquery/z?d107:HR03162:%5D

[18] European Parliament, EU Directive 95/46/EC, Section 2, Article 7, 1995, Data Protection Commission of Ireland, 19 May 2004, http://www.dataprivacy.ie/6aii-2.htm#7

[19] Baase (85)

[20] European Parliament, EU Directive 95/46/EC, Section 6, Article 13, 1995, Data Protection Commission of Ireland, 19 May 2004, http://www.dataprivacy.ie/6aii-2.htm#13

[21] CNN.com NewsNet, High-tech Spy Satellites Not Targeting Americans, CIA, NSA Directors Say, 2000, CNN.com, 8 May 2004, http://www.cnn.com/2000/US/04/12/spies.speak/

[22] Canadian Press, Eavedropping by US Agency Led to Arrests of Terror Suspects: Report, 2004, CNEWS, 15 May 2004, http://cnews.canoe.ca/CNEWS/World/WarOnTerrorism/2004/04/04/408768-cp.html

[23] Baase (36)

[24] Ruth Gavison, “Privacy and the Limits of Law” Computers, Ethics & Social Values, ed. Deborah G. Johnson and Helen Nissenbaum (Upper Saddle River, New Jersey: Prentice-Hall, 1995) 335.

[25] Gavison (333)

[26] James Rachels, “Why Privacy is Important” Computers, Ethics & Social Values, ed. Deborah G. Johnson and Helen Nissenbaum (Upper Saddle River, New Jersey: Prentice-Hall, 1995) 352.

[27] European Parliament, Draft Report: Temporary Committee on the ECHELON Interception System (pg. 108), 2004, The European Parliament, 10 May 2004, http://www.europarl.eu.int/tempcom/echelon/pdf/prechelon_en.pdf

[28] Gavison (335)

[29] Gavison (348)

[30] Campbell