It’s the same spying. The EU Echelon reports described how it works years ago: Because the NSA is legally restricted from spying on US citizens, they hand off their data to the GCHQ/NSA base at RAF Menwith Hill. GCHQ runs the keyword searches and then hands back the results.
That’s why the Director of the NSA feels able to tell congress that they don’t read Americans’ e-mail messages. Technically they don’t, GCHQ does. This arrangement is part of the UKUSA program, and also involves Canada, Australia, New Zealand, and recently a few other countries.
Sadly the Echelon reports were rubbished by NSA sockpuppets back when they came out, and it took the Edward Snowden leaks to confirm the important details about the scope of the surveillance and make people pay attention.
