[burkaman]

From paragraph 64:

> For a detailed description of safeguards that should be set out in law for it to meet the “quality of law” requirements and to ensure that secret surveillance measures are applied only when “necessary in a democratic society”, see Roman Zakharov, §§ 231-34, and Big Brother Watch and Others, §§ 335-39

I am not a lawyer and not motivated enough to go read those decisions, but if anyone is curious that is probably the place to start to figure out what might count as "adequate safeguards".