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User Information Request

Law Enforcement Guidelines


Introduction

This guide is for law enforcement authorities seeking information about Comurce users and accounts in the course of criminal investigations. It is also intended as a reference for Comurce users who are interested in finding out more about our policies and processes for handling law enforcement requests.

Information relating to the request for removal of content from our platform can be found in our Terms of User. General information about our terms and policies is available in our Privacy Policy, Terms of Use and Community Guidelines.

If you are not a law enforcement official and have a request for our team, you can contact us via legal@Comurce.com.

Index

What is Comurce?

Our guiding principles

Jurisdiction

Specificity

User notice

Information stored by Comurce

Public information

Non-public information

Submitting a user information request

English authorities

Foreign law enforcement authorities

How to submit your request

Production of records

Emergency disclosure requests

How to submit an emergency disclosure request

Assisting a Comurce user

Contact details


What is Comurce?

Comurce is a digital transformation platform that enables organisations and their stakeholders whether internal of external to collaborate.

Individuals can access our platform both on computers and via most Android and iPhone devices via our mobile app. You do not need to have an account to access content hosted on Comurce.

In order to avail of our hosting services, individuals must have a registered account. We offer a variety of account types which provide different features, tools and services. You can find out more about our account options on our website and within our App.


Our guiding principles

We believe in respecting both our users’ rights and the laws which govern our company’s operations. When it comes to processing information requests related to our users, we follow the below principles.

Comurce provides software tools for teams to collaborate in an online platform environment. These guidelines provide information to inform law enforcement officials seeking customer account records and customer content (“Customer Information”) from Comurce in response to valid legal process, consistent with our privacy policy and use policy.  Comurce respects the rules and laws of the jurisdiction in which it operates, as well as the privacy and rights of its customers. Accordingly, Comurce provides Customer Information in response to law enforcement requests only when we reasonably believe that we are legally required to do so. To protect our customers’ rights, we carefully review requests to ensure that they comply with the law.

To obtain Customer Information from Comurce, law enforcement officials must provide legal process appropriate for the type of information sought, such as a subpoena, court order, or a warrant. For example, Comurce will not provide non-public customer content unless served with a valid search warrant, issued on a showing of probable cause by a court authorized to issue search warrants, which requires Comurce to disclose the content. Please review these guidelines before submitting a law enforcement request to Comurce.

These guidelines are intended to serve as an informational resource and do not create obligations or waive any objections concerning how Comurce will respond in any particular case or request. Comurce reserves the right to seek reimbursement for the costs associated with responding to law enforcement data requests, where appropriate.

Jurisdiction

We will comply with valid requests for user information received from law enforcement, in accordance with the terms outlined in this guide and the applicable legal process.

We are based in London, England and will therefore process all disclosure requests pursuant to our Privacy Policy and the laws of the England and Wales.

Specificity

We require that all requests be related to specific accounts, implicated in specific investigations undertaken by law enforcement. We reserve the right to reject requests which are overly broad or which lack details regarding the relationship between the requested information and how it relates to an on-going investigation.

User notice

Comurce’s policy is to notify customers of requests for their information and provide them with an opportunity to object to the disclosure 7-10 days prior to production, unless such notification is prohibited by law. Our notice to users will be in writing and will include a copy of the original document(s) requesting their information. Additionally, if the request relates to a user who is in violation of our Terms of Use, we reserve the right to prevent further abuse of our services, including notifying the user regarding their misconduct. Comurce may shorten the notice period in its discretion, but generally only does so in emergency situations.

In exceptional circumstances, we may elect to not provide user notice e.g. in the case of an emergency disclosure request. Law enforcement officials who believe that notification would jeopardise an investigation should obtain an appropriate court order or other process that specifically prohibits customer notification, such as an order issued under the applicable law within the relevant jurisdiction.

Further, if your request places Comurce on notice of an ongoing or prior violation of our use policy, we will take action to prevent further violation, including account termination and other actions that may notify the user that we are aware of the misconduct. If you believe in good faith that taking such actions will jeopardise an ongoing investigation, you may request that Comurce defer such action in your request. Comurce will evaluate such requests on a case-by-case basis. It is the responsibility of the requesting law enforcement official to make this request, as it is Comurce’s policy to enforce its terms of use.


Information stored by Comurce

Some information we store is collected automatically, while other information is entered by the user, at their discretion. While we store the information we are provided, we cannot always guarantee its accuracy or if it relates to a real person. For example, a user may have created a fake profile, or provided us with inaccurate information. We do not require the use of real names, email verification or identity authentication.

Public information

Most account information is public on Comurce, which means that anyone can see it. A Comurce profile may contain: a profile photo, a display name, work history.

Additionally, a user has the option to include their “real name”, location, URLs and a short description about their account in their “bio” section, just underneath their profile image. You do not need a Comurce account in order to view information or content which is posted publicly.

Non-public information

Information not publicly visible, relating to registered users on our platform may include, but is not limited to:

  • Email address(es) associated with the account
  • IP address at the time of account creation
  • IP address of last access to Comurce
  • Month and year of birth

Submitting a user information request

UK authorities

We can only disclose requested information to a competent authority, when we are obliged to do so by applicable law.

Foreign law enforcement authorities

We can only respond to information requests filed by UK authorities. Therefore, we must request that all international law enforcement authorities follow the relevant cross border assistance procedure.

How to submit your request

Your request must be made on law enforcement letterhead, signed by the requesting agent. This can be sent via email, fax or post. Our contact details are provided at the bottom of this guide. Please note that we will not review or respond to any requests from non-law enforcement officials or non-valid email addresses.

All requests for user information must include the following:

  • Requesting agency and law enforcement agent name
  • The profile URL of the Comurce account in question (e.g. Comurce.com/Comurce)
  • Details about the specific information being requested. Please ensure that the information you require is not available on the public profile of the specified account
  • Legal grounds for data disclosure request
  • The reason for your investigations and details about how the requested data relates to your investigation
  • An official, agency-issued email address (e.g. name@agency.co.uk) so that we can verify your identity and get back in touch with you

Production of records

Unless otherwise requested, we will provide records in electronic format (i.e. PDF files), which can be opened with the majority of word processing software.


Emergency disclosure requests

Inline with our Privacy Policy, we may disclose user information in response to a valid emergency disclosure request. If your request relates to an investigation involving the imminent danger of death or serious harm to a person, that we may have information to prevent, law enforcement agencies can submit an emergency disclosure request. International law enforcement authorities may submit requests for emergency disclosure.

How to submit an emergency disclosure request

You must submit an emergency request via email, with the subject line EMERGENCY DISCLOSURE REQUEST. These requests are evaluated on a case-by-case basis and must include all of the following:

  • Identity of the individual in imminent danger
  • Nature of the emergency
  • Comurce profile URL(s) of the account(s) containing information which may prevent the emergency
  • Details of the specific information requested and how it may prevent the emergency
  • Link(s) to any content which may provide further details or context to support your request

Comurce users aware of an emergency situation should contact local law enforcement officials for assistance.


Assisting a Comurce user

Ify ou are assisting a Comurce user with an investigation, and need to obtain a copy of their non-public Comurce account information, please ask the user to contact us directly (contact details below). We can then assist the individual with obtaining the required information.


Contact details

Address:

Comurce Ltd

Attention: Legal Department

Guild House, 1st Floor, Paxford House, GuildStreet, Stratford-Upon-Avon, Warwickshire,  CV376RP, United Kingdom

Email: lawenforcement@Comurce.com 

While we agree to accept service of law enforcement requests by these methods, neither Comurce nor our customers waive any legal rights based on this accommodation.

Each request must include contact information for the authorized law enforcement agency official submitting the request, including:

  • Requesting agency name
  • Requesting agent name and badge/identification number
  • Requesting agent employer-issued email address
  • Requesting agent phone contact, including any extension
  • Requesting agent mailing address (P.O. Box will not be accepted)
  • Requested response date (see details below for emergency requests)

Please note that requests seeking testimony must be personally served on our registered agent for service of process. We do not accept such requests in person or via email.

Non-law enforcement requests for assistance must be submitted via our contact@Comurce.com.


Available Comurce Customer Information

Comurce offers a variety of software tools on its platform that contain Customer Information. In addition, Comurce maintains certain Customer Information in internal systems as a matter of regular business processes. Comurce will review and respond to requests for Customer Information pursuant to a valid, enforceable government request, court order and/or warrant, depending on the type of information requested.

The categories of Customer Information that may be available for law enforcement requests seeking basic customer account information, include, for example: email address, name, phone number, screen name, instant messenger ID and/or billing contact information (in connection with paid accounts). Additional information regarding IP addresses, transactional records and other customer records may be available.

The categories of Customer Information that may be available to law enforcement requestors depends on which Comurce product is used by the customer about whom law enforcement seeks information. We encourage law enforcement officials making a request for Comurce Customer Information to review our product descriptions before preparing legal process and submitting your request, order or warrant. For example, Comurce Project & Portfolio Management enables teams to organize information. Available Customer Information involving Comurce Project & Portfolio Management might include, in addition to basic account information, IP access information, board member information and/or content, IP addresses associated with log-ins to a user account and team memberships. As a third example, Slack provides team chat and messaging functions. Available Customer Information using Slack might include, in addition to basic customer account information, IP addresses associated with log-in information and chat messages (content).

Law Enforcement Preservation Requests

Comurce will preserve Customer Information for 90 days upon receipt of a valid law enforcement request. Comurce will preserve information for an additional 90-day period upon receipt of a valid request to extend the preservation. If Comurce does not receive formal legal process for the preserved information before the end of the preservation period, the preserved information may be deleted when the preservation period expires.

Preservation requests must be sent on official law enforcement letterhead, signed by a law enforcement official, and must include:

  • The relevant account information identified below for the customer whose information is requested to be preserved;
  • A valid return email address; and
  • A statement that steps are being taken to obtain a court order or other legal process for the data sought to be preserved.

​Preservation requests may be sent to the contact information (mailing address or email account) provided, above.

How to request Comurce Customer Information

When requesting Customer Information, law enforcement requestors should provide as much of the following information as is available. Providing the following identifying information will facilitate Comurce’s ability to respond in an effective and timely manner:

  • Basic Customer Account Information (Comurce systems): Username, email address, URL, Support Entitlement Number (SEN)
  • Customer Information involving Comurce products:
Comurce Product Information to Include in Law Enforcement Request

Agile Project & Portfolio Management

User ID, username, email address, IP address, URL (for board(s), etc), SEN

Agile Product Development

User ID, username, email address, IP address, URL (for board(s), etc), SEN

Agile Governance & Reporting

User ID, username, email address, IP address, URL (for board(s), etc), SEN

Agile Finance

User ID, username, email address, IP address, URL (for board(s), etc), SEN

Skills & Capability Management

User ID, username, email address, IP address, URL (for board(s), etc), SEN

Security Management

User ID, username, email address, IP address, URL (for board(s), etc), SEN
Slack User ID, email address associated with the user account, and/or Slack Channel group name and group administrator’s email address

International Law Enforcement

U.K. law authorises Comurce to respond to requests for Customer Information from foreign law enforcement agencies that are issued via a U.K. court either by way of a Mutual Legal Assistance Treaty (MLAT) request or letter rogatory.  It is our policy to respond to such U.K. court-ordered requests when properly served. Comurce will evaluate emergency requests from foreign law enforcement on a case-by-case basis, consistent with U.K. law and the laws of other countries, if applicable. Emergency requests may be submitted directly to Comurce via the procedure described below.

Emergency Requests

Comurce evaluates emergency requests on a case-by-case basis. If you provide information that gives us a good faith belief that there is an emergency involving imminent danger of death or serious physical injury to any person, we may provide information necessary to prevent that harm if we are in a position to do so, consistent with applicable law.

Emergency requests may be submitted via email to lawenforcement@comurce.com with the subject line: “Emergency Disclosure Request” and completing and sending this form.

Last amended: February 2019

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Phone: +44 (0)20 3890 5583