Kuhn: Copyleft Won't Solve All Problems, Just Some of Them

> a technological measure “effectively controls access to a work” if the measure, in the ordinary course of its operation, requires the application of information, or a process or a treatment, with the authority of the copyright owner, to gain access to the work.

If you wrote and distributed the program without the copyright holder's authority, then the program (if it works at all) does not require the authority of the copyright holder to operate, therefore the program is not a "technological measure that effectively controls access to" that work.

The program might be deemed to "circumvent a technological measure", but it cannot *be* a technological measure, which is what the GPL is talking about.