BPD
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BPD was explained as follows by the Respondents in their Response dated
11th April 2016 (“the April Response”):"(1) A Bulk Personal Dataset ... is a dataset that contains personal
data about individuals, the majority of whom are unlikely to be of
intelligence interest, and that is incorporated into an analytical system
and used for intelligence purposes. Typically such datasets are very
large, and too large to be processed manually.
(2) The [SIAs] obtain and exploit BPD for several purposes:
- to help identify subjects of interest or unknown people that surface in
the course of investigations;
- to establish links between individuals and groups;
- or else to improve understanding of targets' behaviour and
connections;
- and to verify information obtained through other sources.
(3) BPD obtained and exploited by the [SIAs] includes a number of
broad categories of data. By way of example only these include:
biographical and travel (e.g. passport databases); communications
(e.g. telephone directory); and financial (e.g. finance related activity of
individuals).
(4) While each of these datasets in themselves may be innocuous,
intelligence value is added in the interaction between multiple
datasets. One consequence of this is that intrusion into privacy can
increase.
(5) BPD is operationally essential to the [SIAs] and growing in
importance and scale of holdings. Examples of the vital importance of
BPD to intelligence operations include ... identifying foreign fighters
[and] preventing access to firearms."
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The ISC in its March 2015 Report gave the following description of BPD:"157. Whereas the [SIAs’] capabilities to intercept communications
and acquire Communications Data are regulated by [the Regulation of
Investigatory Powers Act 2000] (RIPA) the rules governing the use of
Bulk Personal Datasets are not defined in legislation. Instead, the
[SIAs] derive the authority to acquire and use Bulk Personal Datasets
from the general powers to obtain and disclose information (in support
of their organisation's functions) that are afforded to the heads of each
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