The New York Times is reporting that the NSA developed a way to spy on our emails even after the program allowing it to do so was shut down. Until December 2011, the agency was entitled to bulk-collect emails at will because it was subject to oversight from the intelligence court. That meant that the data had to be used according to the regulations laid down by the Foreign Intelligence Surveillance Act. The NSA, however, had a second, more secretive program, based overseas, that did a similar job, but was under no such legal restriction. As such, when its powers were curtailed, it simply went back to doing what it always did, but in a foreign country.
Source: New York Times, (2)
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