That Litt letter invents a new definition of bulk communication.
They're collecting bulk, for better and worse, to do analysis they say requires bulk -- all. @maxschrems
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PPD-28 footnote 5 seems to exclude data collected (in bulk) for later targeted collection from the definition of bulk collection
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So, eg, I'd expect they do a lot of XKS on UK switches (to extent that's still EU) but might get bulk fr areas w/heavy refugee pop.
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GCHQ, DDIS etc, operate outside European Union law. So they get to do the bulk collection which CJEU does not allow NSA to do..
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I sort of suspect they'd move a data processing center to Ireland (in shadow of MSFT, maybe) if that became problem.
End of conversation
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