Any creep with a digital camera

Can invade a woman's privacy without her even knowing:

...it's not only upset ex-boyfriends or other vengeful characters that are keeping prosecutors busy. Peeping Toms who film women secretly are also highly active. They use camera phones or tiny digital cameras to provide the sex-hungry Internet community with fresh voyeuristic material around the clock: footage of changing rooms, public toilets, swimming pools or tanning booths.

In 2004, Google listed about 4 million sites featuring the search words "upskirt" and "downblouse." Now the number has climbed to almost 8 million. Some links lead to popular websites like MyVideo, accessed by millions of people every day. "There are countless women out there who have no idea they're being presented nude or semi-naked on such Internet sites," says Maeser from Bavaria's Office of Criminal Investigation.

It's often difficult enough for the investigators to convict the perpetrators if they happen to catch them. But preventing the further circulation of such images is entirely impossible. If they appeal to Internet users, they're downloaded hundreds of times within just a few hours, and then traded and passed on. And so lawyer Tobias Strömer can only advise his clients to get used to the idea of featuring in a permanent online peep show: "This will never end for you," he says.

And it is so easy to do.