"PRISM. The utility collates data that the companies are required to provide under the Foreign Intelligence Surveillance Act -- unless, crucially, it's encrypte

"PRISM. The utility collates data that the companies are required to provide under the Foreign Intelligence Surveillance Act -- unless, crucially, it's encrypted and the government doesn't possess the key." Couldn't they just use a hand-wavy encryption like a caesar cipher that meets the legal requirements without actually making storage any harder?