Blackthorn is committed to ensuring the integrity of our platform whilst also protecting our customers and their personal information.
Purpose: This document outlines company policy and procedure for dealing with valid information requests received by fully authorised law enforcement officials and or financial institutions.
Scope: All Blackthorn employees should play their part in maintaining the integrity of our platform. Information requests should be received, acknowledged and directed to the correct team in order to be accurately assessed.
1. Requests for Information
Blackthorn will only respond to information requests from authorised law enforcement agencies and or Regulated Financial Institutions officials who provide:
Proof of authority to request information, including the name of the issuing authority;
The badge and ID number of responsible agent;
The email address from a government domain; and The order is received by way of a formal Production Order approved by the relevant judicial authority
The Bank Indemnity confirms to jurisdictional requirements
A direct contact number at the requesting governmental agency
Requests should be sent to [email protected]
2. Disclosures
Blackthorn discloses records solely in accordance with our customer agreement, terms, policies and applicable law in the relevant jurisdiction.
Overly broad or vague requests for information will not be accepted. The request should specifically identify the required records and include accurate information that allows us to identify the customer account(s) at issue.
3. Account Preservation
Blackthornwill take steps to preserve records in connection with official investigations in accordance with the preservation of records requirements within each jurisdiction for 90 days pending receipt of formal legal process.
4. Data Retention
Blackthorn will search for and disclose data that is specified with particularity in an appropriate form of legal process that we are reasonably able to locate and retrieve. We do not retain data for law enforcement purposes unless we receive a valid preservation request. Our Privacy Policy and Data Policies contain information about what information may be available and the records that we are required to retain for regulatory and legislative purposes.
5. Customer Consent
If law enforcement and or a financial institution is requesting information about a customer who has provided consent to access or obtain the account information, without a formal production order or Bank Indemnity the customer will be instructed to obtain that information from Blackthorn directly.
No third-party requests to divulge information, regardless of having a customer consent is permitted. In these instances, the information should be sent directly to the customer via normal communication channels and to the customers’ existing address, email etc.
6. Customer Notification and Legal Process
Blackthorn is founded on the principle of complete transparency. Our policy is to notify customers of requests for information relating to them prior to disclosure unless we are prohibited by law from doing so, or if that notice may jeopardise a criminal investigation.
If a request received by a law enforcement official draws attention to abuse of our Service, unless otherwise instructed we will take action to prevent further abuse, including actions that may indicate to the customer that we are aware of potential misconduct.
