Barack Obama's admission that America's intelligence community requires substantial reform may not have gone far enough to satisfy US privacy campaigners, but it was sufficiently robust to highlight the gulf between the way the disclosures of widespread government surveillance have played out on different sides of the Atlantic.

In his 45-minute speech the US president conceded that "dizzying" technological advances since 9/11 had transformed intelligence agencies' work and challenged their legal and oversight regimes.

He defended the need for them to have secret capabilities, but agreed with calls for them to be more transparent, adding that "the work has begun".

The same could not be said for the UK. Untroubled by the kind of political brouhaha Obama has faced, Downing Street and the chiefs of the intelligence agencies have refused to acknowledge there is a need for any debate at all, let alone consider reforms to the bodies and laws that govern the conduct of British spies.

Speaking hours before Obama, William Hague, the foreign secretary, reiterated his belief that the UK has the world's strongest system of regulation, and that the agencies had not breached it.

"I can say [we have] a very strong system of checks and balances, of warrants being required from me or the home secretary to intercept the content of the communications. I have not seen anything to suggest that system has been breached. We have probably the strongest system in the world."

Interviewed by the BBC today, the Guardian's editor-in-chief, Alan Rusbridger, said this was "laughable".

Obama's speech also put the spotlight on a former Conservative foreign secretary who now has to try to follow in the footsteps of the world's most powerful man.

Malcolm Rifkind, who was once in overall charge of GCHQ and MI6, is the chair of the parliamentary intelligence and security committee (ISC), to which Britain's agencies are answerable.

There are commissioners who look at the decisions taken by ministers, and there is the Investigatory Powers Tribunal (IPT), which assesses complaints made by members of the public about agency activity.

Yet, over the past decade, none of them has reported a single word on the techniques revealed by NSA whistleblower Edward Snowden, or raised questions about whether UK law needs updating in the light of them, or asked whether the technologies used by GCHQ and the NSA were proportionate. The IPT has never ruled against a UK spy agency.

The laws governing Britain's agencies were drafted before the technological transformation referred to by Obama, but ministers have dismissed calls to look at them again.

Rifkind and his committee have been accused of being establishment patsies, without proper expertise or resources. Yet it is the ISC that has been left to carry out the official Westminster inquiry into mass surveillance by GCHQ.

"The various oversight bodies have failed to inform the public or parliament anywhere near properly, as recent revelations of mass surveillance have exposed," said Nick Pickles, director of Big Brother Watch.

"They continue to hide behind needless secrecy and without any meaningful way for them to be properly accountable for their failures to defend our privacy and civil liberties. All too often they have appeared to act as spokesmen for the agencies rather than the independent oversight we so badly need." Obama promised to curtail the activities of US spying on foreign leaders and proposed new public advocates to represent privacy concerns before the NSA is given authorisation for certain activities. No such commitment has been given by the British government.

The Liberal Democrats have got closest to stirring a debate, and Nick Clegg wants to raise the issue at the party conference in March. But Pickles said it was "clear that Britain is already lagging behind the US in terms of surveillance oversight and accountability, with no involvement of courts or meaningful transparency.

"That gap is set to widen further still and that should be a call to action for parliament. President Obama emphasised the need for judicial oversight by courts, greater transparency by the Government and for the legal basis of surveillance programmes to be public. All of these issues should be pursued in Britain to protect our privacy and our economy."

Whether they are depends on Rifkind, who has found himself in charge of Britain's official response to Snowden's disclosures. Though he has been criticised for being too ready to defend the agencies, he knows the ISC is in Westminster's last-chance saloon. If the committee fails to match even the limited ambition of Obama's speech, then it will be accused of a whitewash, and lose whatever residual credibility it still has.

Privacy campaigners hope Rifkind will not want to end his long political career as the last chair of a much-lampooned scrutiny committee that failed to scrutinise. He has boasted that he has more money and more powers than his predecessors, and sources in Whitehall say he is beginning to ruffle feathers. Ministers were taken a back by his abrasive response to the suggestion the ISC pick up the pieces of the Gibson inquiry into the kidnap and torture of detainees.

Having given short shrift to a senior civil servant, he was only persuaded to take it on with promises of more money and extra staff.

After Obama's address, Rifkind knows the system of British scrutiny he has been so determined to defend, as much as the agencies themselves, is now under the spotlight too.