Conspiracy Wiki · Commentary

The Other Half of the Grid

The American surveillance grid left a question open and named it: what the partners are permitted to do. Here are nine British powers under the same four questions, and the row with no instrument behind it at all — material a partner collected and passed on. The laundering claim turns out to be half answered by a statute almost nobody quotes, and half not answered at all.

October 21, 2026 · Conspiracy Wiki

Nine powers, the same four questions

The American grid asked who can be targeted, who approves it, content or metadata, and whether anyone is ever told. Asked of the United Kingdom, the 36 answers below include 8 that are tightly bound and 12 with no constraint at all — and the last column is almost entirely one answer. The grid is ordered from the most constrained power to the least. Open any cell for the provision behind it.

Each cell is graded by what the Act actually requires for that element, not by how intrusive the power is overall.
Power	Who can be targeted?	Who has to approve it?	Content, or only metadata?	Is anyone ever told?
Targeted interception warrantIPA 2016 Part 2 — the baselineOrdinary targeted interception, and the most constrained power on this page. It is here as the measure everything below is read against.	Tightly boundA named person, organisation or premises The warrant must name or describe its subject. The Act also permits a thematic warrant covering a group who share a common purpose or are part of a single investigation, which is the point critics press on: the subject can be a described category rather than a named individual, and the number of people inside it is not fixed when the warrant is signed.	Tightly boundA Secretary of State, approved by a judge The double lock: a Secretary of State issues the warrant and a Judicial Commissioner must approve it before it has effect, applying the principles of judicial review. In an urgent case the warrant can take effect first, but a Judicial Commissioner must approve it within three working days or the material is destroyed.	Tightly boundContent, bound to stated purposes Content and secondary data, which may be examined only for the operational purposes specified in the warrant. The purposes are written into the instrument, not chosen afterwards.	UnboundNo There is no notification requirement anywhere in the Act. The only route by which a person learns they were intercepted is section 231: the Investigatory Powers Commissioner may inform them of a relevant error, but only if it is serious and only if telling them is in the public interest.
Targeted examination warrantIPA 2016 Part 2 — the hinge of the whole schemeNot a power to collect anything. It is the permission needed before material already taken in bulk can be read, where the person it belongs to is in the British Islands.	Tightly boundA person in the British Islands whose material is already held This row exists because of a prohibition. Under section 152, content gathered under a bulk warrant may not be selected for examination using criteria referable to an individual known to be in the British Islands, where the purpose is to read what that person sent or received. A targeted examination warrant is the authorisation that lifts it.	Tightly boundA Secretary of State, approved by a judge The same double lock as a targeted interception warrant, which is the design: the Act accepts that reading a British resident's communications should cost the same whether the material was collected deliberately or swept up.	Tightly boundContent already collected Nothing new is intercepted. What changes is permission to look, which is why the distinction between collection and examination carries so much weight in the British scheme and so little in the public argument about it.	UnboundNo Section 231 again, and nothing else.
Targeted equipment interferenceIPA 2016 Part 5Interference with equipment — a phone, a computer, a server — to obtain communications, equipment data or any other information.	Tightly boundNamed equipment, person or location The warrant describes the equipment or the person it belongs to. As with interception, thematic descriptions are available where a group shares a purpose or an investigation.	Tightly boundA Secretary of State or chief officer, approved by a judge Double locked. Law enforcement warrants are issued by a chief officer rather than a minister, and still require a Judicial Commissioner's approval.	Loosely boundWhatever is on the device This is the element where a tightly authorised power reaches furthest. Interception takes a communication in transit; equipment interference takes what is stored — messages already read, photographs, location history, drafts never sent — and can also turn on what the device can sense.	UnboundNo Section 231 again.
Communications data authorisationIPA 2016 Part 3The who, when and where of a communication rather than its content: subscriber details, call records, which service was used from which address.	BoundedAnyone whose data is relevant to a specific investigation Hundreds of thousands of authorisations are granted a year, by a wide range of public authorities, for purposes running from national security to the detection of crime.	BoundedAn authorising office, not a minister or a court Law enforcement applications go to the Office for Communications Data Authorisations, which sits under the Investigatory Powers Commissioner. There is no double lock here. The exception is an application to identify or confirm a journalistic source, which does require a Judicial Commissioner.	BoundedMetadata only No content. The familiar objection is that for most purposes the pattern is more revealing than the message, and the Act's own structure concedes the point by treating bulk acquisition of the same data as a power requiring the double lock.	UnboundNo Section 231 again.
Bulk interception warrantIPA 2016 Part 6, Chapter 1The power the Five Eyes argument is really about: interception at scale, of communications crossing the network rather than of a named person's traffic.	Loosely boundAnything overseas-related The warrant's main purpose must be to obtain overseas-related communications, which section 136 defines as communications sent or received by individuals outside the British Islands. One party abroad is enough, so a British resident's communications fall inside the definition whenever the person at the other end is not here.	BoundedA Secretary of State, approved by a judge Double locked, which is the sharpest difference from the American equivalent: Section 702 collection runs on an annual certification approved by a court that reviews the procedures rather than the targets, while a British bulk warrant is individually approved by a Judicial Commissioner. What is approved, though, is a programme, not a person.	Loosely boundContent and secondary data, read under limits Collection is broad and examination is narrow. Material may be selected only for the operational purposes written into the warrant, and the section 152 prohibition stands in front of anyone known to be in the British Islands. The constraint in this scheme is at the point of reading rather than the point of taking.	UnboundNo Section 231 again.
Bulk acquisition of communications dataIPA 2016 Part 6, Chapter 2A direction to a telecommunications operator to hand over communications data in bulk, rather than a request about one investigation.	Loosely boundEveryone on an operator's network The subject is a dataset, not a person. Whether an individual's records are in it has nothing to do with whether they are of any interest.	BoundedA Secretary of State, approved by a judge Double locked since 22 August 2018, which is later than the rest: bulk personal datasets and bulk communications data were the last two powers brought inside the new approval regime after the Act commenced.	BoundedMetadata only No content. The volume is the point.	UnboundNo Section 231 again.
Bulk equipment interferenceIPA 2016 Part 6, Chapter 3Equipment interference at scale, aimed at equipment outside the British Islands.	Loosely boundEquipment abroad, in quantity The warrant's purpose must relate to overseas equipment. As with bulk interception, material belonging to someone in the British Islands cannot be examined without a targeted examination warrant.	BoundedA Secretary of State, approved by a judge Double locked, and available only to the intelligence services — not to police forces.	Loosely boundWhatever the equipment holds The widest reach on the page in terms of what a single operation can produce, and the hardest to describe in the abstract, because what it returns depends entirely on what the equipment was doing.	UnboundNo Section 231 again.
Bulk personal datasetsIPA 2016 Part 7Not interception at all: datasets about populations, held and searched by the intelligence services.	Loosely boundPopulations, by statutory definition The Act defines the power by the irrelevance of most of the people inside it. A bulk personal dataset is one where the majority of individuals are, in the statute's words, not and unlikely to become of interest to the intelligence service. That is the definition, not a criticism of it.	BoundedA Secretary of State, approved by a judge Double locked since 22 August 2018, by class warrant for a category of datasets or by specific warrant for one.	Loosely boundWhatever the dataset contains Travel records, financial records, communications data, registers. The limit is what exists in collectable form, not what the Act enumerates.	UnboundNo Section 231 again.
Material received from a partnerNo warrant of its ownWhat a Five Eyes partner collected under its own law and passed on. This row is why the page exists, and it is the only one with no instrument behind it.	UnboundWhoever the partner collected The British Islands restriction binds British collection. It does not bind what another country's service lawfully gathered under its own rules, and a British resident's communications can sit inside that material for reasons that have nothing to do with any British warrant.	UnboundNobody, to receive it There is no warrant to receive intelligence. There is a restriction on asking for it: section 9 forbids a person in the United Kingdom from requesting an overseas authority to intercept someone they believe is in the British Islands unless a targeted interception or examination warrant already authorises it here. The request is regulated. The receipt is not.	UnboundWhatever the partner holds Content, metadata, or the product of a programme with no British equivalent.	UnboundNo Section 231 again, and the error would have to be a British one.

Tightly bound: Individualised approval by a minister and a judge, or the equivalent.
Bounded: A judicial commissioner or a statutory standard is involved, but the subject is a class rather than a person.
Loosely bound: Approval exists but is programmatic, or the category it covers is drawn wide enough to include almost anyone.
Unbound: No approval of any kind is required for this element.

The last column is one answer, nine times

9 of 9 powers under which nobody is ever told

The American grid had one authority out of eight that notifies its targets, and that provision explained the shape of everything below it. The British Act has no notification requirement at all. The only route by which a person learns they were intercepted, interfered with or searched is an error report: the Investigatory Powers Commissioner may tell them, but only if the error caused significant prejudice or harm — a breach of their Convention rights is expressly not enough on its own — and only if telling them is in the public interest.

Investigatory Powers Act 2016, s.231. The Commissioner may not inform a person of a relevant error except as that section provides.

The question the American grid refused

The surveillance grid set eight American authorities against four questions and declined to open a fifth: what the partners are permitted to do. It named that as a subject of its own. This is it.

The arrangement has a name and a date. The UKUSA agreement was signed in March 1946, grew out of a 1943 wartime accord, and was extended to Canada in 1948 and to Australia and New Zealand in 1956. It was not acknowledged in public for most of its life. The text was declassified by the NSA and GCHQ together on 24 June 2010, covering 1940 to 1956, which is the unusual part: the founding document of the thing most often described as unaccountable can be read online, and the agencies published it themselves.

What cannot be read is anything equivalent about the present. So the grid above does what the American one did — takes the powers one at a time and asks the four questions of each — and then adds the row that has no instrument behind it.

The British scheme constrains reading, not taking

The single structural difference from the American arrangement is worth stating before anything else, because most arguments about British surveillance are conducted without it.

American law mostly draws its line at collection: Section 702 may not target a US person, and the protections attach to who may be acquired. The Investigatory Powers Act draws its line in a different place. Bulk interception is permitted where the main purpose is to obtain overseas-related communications — and section 136 defines that as communications sent or received by individuals outside the British Islands, so one party abroad is enough. A British resident's messages are inside the definition whenever the person at the other end is not here.

What then protects the resident is not a limit on what was collected but a prohibition on reading it. Under section 152, content taken in bulk may not be selected for examination using criteria referable to an individual known to be in the British Islands where the purpose is to find out what that person sent or received. Lifting that prohibition requires a targeted examination warrant, which goes through exactly the same double lock as a warrant to intercept the person directly: a Secretary of State, and a Judicial Commissioner applying judicial review principles.

There is one exception, and it has a clock on it. If the person enters the British Islands, a senior officer may authorise examination in writing without a warrant, but only until the end of the fifth working day after the change of circumstances, and the Secretary of State must be told.

Whether reading-side control is weaker or stronger than collection-side control is a real argument. It is not the argument people usually have, which tends to assume the British scheme has no equivalent of the American rule at all.

The laundering claim, which is half answered

The claim that gives this subject its energy is specific: that partners spy on each other's nationals and trade the results, so that each service obtains by alliance what it is forbidden to collect at home.

Half of that is addressed by a provision almost nobody quotes. Section 9 of the Act is headed Restriction on requesting interception by overseas authorities, and it says that a person in the United Kingdom may not ask an overseas authority to intercept the communications of someone they believe will be in the British Islands unless a targeted interception or targeted examination warrant already authorises that interception here. The request route is closed by the same instrument that would have been needed to do it directly. The interception code of practice goes further and requires the UK authority to hold a warrant where the overseas authority would not otherwise have been intercepting that person at all, with the material then handled under the same internal safeguards as material collected under the Act.

The other half is not addressed, and the grid's last row is where it sits. There is no warrant to receive intelligence. If a partner collected material under its own law, for its own reasons, and a British resident is in it, no British instrument governs the handover. Section 9 regulates asking. Nothing regulates arriving.

What the courts have said about the half that is open

This is not an untested gap. It has been litigated twice, and the two results point in different directions, which is the honest shape of it.

In February 2015 the Investigatory Powers Tribunal held that the regime governing British access to material from the American PRISM and Upstream programmes had been unlawful until December 2014 — not because the sharing was improper in itself, but because the rules governing it were secret, and a secret rule cannot satisfy the requirement that an interference with private life be in accordance with law. It became lawful at the moment the policies were disclosed during the proceedings. It was the first time in the Tribunal's fifteen-year history that it ruled against the intelligence services.

In May 2021 the Grand Chamber of the European Court of Human Rights decided the other way on the same question. It found the old RIPA bulk interception regime in violation of Articles 8 and 10 — authorised by a Secretary of State rather than a body independent of the executive, with search terms linked to an individual not subject to prior independent authorisation — while holding, by twelve votes to five, that the regime for requesting and receiving intelligence from foreign partners did not violate Article 8.

So: the sharing arrangement was unlawful while its rules were secret, and lawful once they were published, and a court of seventeen judges split five ways on whether the published version is enough. Anyone who tells you this question is settled in either direction is describing one of those rulings and not the other.

The column that does not vary

The American grid found that one authority out of eight notified its targets, and that this single provision explained the shape of everything beneath it.

The British answer is simpler. There is no notification requirement in the Act at all. Nine powers, one answer, nine times. The only route by which a person ever learns they were intercepted, interfered with or searched is section 231: the Investigatory Powers Commissioner may inform them of a relevant error, but only if the Commissioner considers it serious, and an error is not serious unless it caused significant prejudice or harm — the Act says in terms that a breach of the person's Convention rights is not enough on its own. Even then, the person is told only if that is in the public interest, and the Commissioner may not tell them by any other route.

The practical consequence is the one this archive keeps running into. A British resident who suspects they were surveilled cannot find out. They can complain to the Tribunal, which investigates in private and, where it finds nothing improper, returns a determination that does not disclose whether there was any surveillance at all.

What people do when nobody is ever told

If the state will not tell you, the remaining route is records law — and the clearest demonstration of what that produces is not British at all. It is American, it concerns a private company rather than an intelligence agency, and it is worth putting next to section 231 because the contrast is so stark.

Flock Safety sells automated number-plate recognition to American police forces and private communities: cameras on public roads, images to the company's servers, plates and vehicle characteristics indexed into a database shared across its customers. When an officer runs a plate, the system records who searched, when, and the reason they typed in. Those audit logs are government records, which in many American jurisdictions makes them obtainable.

Three independent projects have been built on that opening, and none of them is affiliated with the company.

Have I Been Flocked aggregates audit logs released through open-records requests and transparency portals, and lets anyone check whether their own plate appears in them. Its published figures as of early October 2026 are 243,098,172 searches covering 4,686,527 distinct plates, drawn from 6,598 organisations, with the earliest record from December 2021. The project says plainly that the dataset is incomplete and lagging — few agencies release the logs readily, what arrives is often redacted, and a result shows that somebody queried your plate, not that you were stopped or investigated. It also states the fact that makes the rest of it matter: many agencies require neither a warrant nor suspicion before running a search.
DeFlock maps where the cameras are. It is a volunteer project begun in late 2024 that writes its pins into OpenStreetMap rather than a private database, so the map it produces belongs to nobody. Tallies of ALPR-tagged features in that dataset ran to roughly 128,000 in the United States by August 2026, against the company's own estimate of 120,000-plus devices.
Eyes on Flock works the other seam, aggregating and analysing the public transparency portals the company provides to its customers, to track cameras, searches and data sharing between agencies.

All three are advocacy projects and say so, and their numbers are floors rather than counts: they describe the portion of a private system that public-records law has pried loose, which is why the totals move whenever another force answers a request.

Set that against the row above. A British resident subject to any of the nine powers on this grid learns nothing, ever, unless the Commissioner decides an error was serious enough. An American motorist can type a plate into a website and find out how many times it was queried, by which agency, and what reason the operator typed — for the subset of forces whose records someone has already extracted.

Neither of those is accountability in the sense the word usually implies. One is silence by statute. The other is a volunteer reconstruction of a commercial database, assembled a records request at a time. But only one of them produces a number, and the gap between them is the practical meaning of a notification regime that exists only for errors.

What this grid cannot establish

It describes authorities, not conduct. Every row says what the Act permits and who must approve it; none of them says what was done last year, because that is not public and the grid would be inventing it.

It covers one partner of five. The other four — the American authorities are in the companion grid, and Canada, Australia and New Zealand have statutes of their own — are not here, and the arrangement between them is governed by instruments that have not been published for the period that matters.

And it cannot tell you the size of anything. The constraint that bites in this scheme is at the point of examination, which is exactly the point at which no public figure exists: the number of targeted examination warrants is not broken out in a way that answers the question people are actually asking, and the volume of material arriving from partners is not reported at all.

What the record does establish is narrower and worth holding onto. The request route is closed by statute. The receipt route is not closed by anything. One tribunal found the receipt regime unlawful for as long as its rules were secret, and one court found the published version compatible by a majority of twelve to five. And whichever way that question goes, nobody affected by it will be told.