On 6 January 2025, the UK Home Office closed its consultation on a Code of Practice for Intelligence services' use of third party bulk personal datasets (3PDs). The Code provides procedural guidance for intelligence services on accessing and examining bulk personal datasets held by third parties. The Code outlines the legal framework governing such access, emphasising the necessity of obtaining a 3PD warrant from the Secretary of State, which must also be approved by a Judicial Commissioner. The Code further delineates the requisite safeguards to ensure compliance with human rights protections, particularly Article 8 of the European Convention on Human Rights, which protects the right to privacy. The Code also mandates record-keeping, oversight, and reporting mechanisms, including the role of the Investigatory Powers Commissioner in auditing compliance and addressing errors. Finally, it includes special provisions for sensitive information, such as legally privileged material, journalist sources, and communications involving members of a relevant legislature.
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