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High Severity

Warrantless Data Access Without Judicial Oversight

Inspectors can enter premises, vehicles, and aircraft to examine "records or documents related to ICT transactions" without requiring a warrant or judicial authorization beforehand. This permits access to potentially sensitive customer data, communications records, and personal information held by ICT service providers based only on "reason to believe" unlicensed activity exists. While 69(4) requires tribunal validation within 7 days after seizure, the data examination occurs before any judicial oversight. This approach departs from GDPR and ECHR standards requiring judicial authorization before accessing private records, creating significant privacy risks for data subjects whose information is held by ICT businesses.