Re: Difference?
In the UK, even prisoners have the right to a private conversation with their lawyer, although I recall therefore some instances of the rooms being bugged in some prisons.
https://www.rahmanravelli.co.uk/articles/stop-bugging-us/
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The starting point is the Regulation of Investigatory Powers Act 2000 (RIPA). RIPA provides a statutory backcloth to all covert police operations so that all such operations must be properly authorised. This requirement for proper authority emanated not from a Government desire for its citizens to know and understand the power of the authorities; but because it had to under human rights law. Article 8 of the European Convention of Human Rights established, even before the Human Rights Act 1998 came into force, the right to privacy. Any surveillance is a breach of privacy. Of course, surveillance is also a necessary and legitimate tool in the fight against crime. The problem is getting the balance right between allowing the State to watch us and preventing law enforcement authorities from becoming oppressive 'Stasi' type agencies paying no regard to our rights. The Human Rights Act is the protection from State abuse.
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