Stumbled upon IMP FOI doc (WAS: Consultation on change to RIP interception definition)

James Firth james2 at
Thu Nov 11 13:54:40 GMT 2010

Ian Batten wrote:

> On 10 Nov 2010, at 09:58, Richard Clayton wrote:
> > lawful-intercep/ripa-amend-effect-lawful-incep
> While searching on the website to try to deal with the mangling of the
> URL (looks like Turnpike is line folding on '-' a URL in text/plain,
> which my client then won't reassemble) I stumbled on this:
> information1/foi-archive-
> crime/12307_docs_used_prep_APPG_IMP/12307_1_docs_prep_APPG_IMP?view=Bin
> ary

Does anyone have any idea as to the date for this FOI-released document?

Reading the references to "third party data" followed by reference to
practical problems related to separating communications data from content
this reminds me of the stretching of the definition of "communications

Surely when traffic data for a third-party service is embedded in a protocol
carried by a CSP then that CSP must treat the embedded protocol as content,
not traffic data.

Someone earlier spoke of the need to revisit the doormat, however a strict
definition of traffic data may be necessary to avoid falling foul of the
strict definition of traffic data in S15 of Directive 2002/58/EC:

"(15) A communication may include any naming, numbering or addressing
information provided by the sender of a communication or the user of a
connection to carry out the communication. Traffic data may include any
translation of this information by the network over which the communication
is transmitted for the purpose of carrying out the transmission. Traffic
data may, inter alia, consist of data referring to the routing, duration,
time or volume of a communication, to the protocol used, to the location of
the terminal equipment of the sender or recipient, to the network on which
the communication originates or terminates, to the beginning, end or
duration of a connection. They may also consist of the format in which the
communication is conveyed by the network."

James Firth

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