4.

New facts

53.

The Applicants also wish to draw the Court’s attention to new evidence,
which has come to light since July 2015 (the month of the Applicants’ last
submissions in this case) and which has not been addressed in the
Government’s Observations.

54.

These facts concern the publication in September 2015 of details of the
GCHQ programmes named KARMA POLICE, Black Hole and MUTANT
BROTH. They shed important light on the ways in which the UK
Government uses bulk interception to create detailed profiles of
individuals around the world, whether or not they are of legitimate
intelligence interest.

55.

The Applicants develop these facts further for the Court in the Factual
Appendix. It is important to note that the Applicants have done so not in
order to ask this Court or the Government to make express findings or
admissions about new allegations. The relevance of these new facts /
allegations is to illustrate what is happening – or could be carried out –
within the existing legal framework. Whether or not they are avowed or
proved, the new facts illustrate that the lack of legal safeguards in UK law
permit

significant

and

extensive

Government

interferences

with

communications.
5.

Intrusiveness of interception of content and communications data

56.

This Court has long recognised the intrusiveness inherent in government
interception of the content of communications. In Klass, the Court held
that “telephone conversations” are “covered by the notions of ‘private life’
and ‘correspondence’” referred to in Article 8 (§41). Since Klass, the advent
of the internet and

advancements in modern technologies have

revolutionised the way we communicate. The Court has acknowledged

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