Privacy Policy - Corporate Investigator .Com is a wholly owned subsidiary of Alexander Moore & Associates Limited, a company limited by liability in England & Wales.

Email/Internet Policy

1. Purpose

Corporate Investigator .com ("the subsidiary of John Moore & Sons (1972) Limited), a private investigator agency, invests substantially in information technology and communications systems that enable our employees to work efficiently. We recognise that the email communication plays an essential role in the conduct of our business and that the way in which our employees communicate with people not only reflects on them as individuals but also on us as an organisation.

In addition, we provide access to the vast information resources of the Internet and the World Wide Web to help employees do their job and be well informed. The facilities that we provide represent a considerable commitment of resources. This policy is designed to help employees understand our expectations for the use of those resources and to ensure that our employees use those resources wisely.

2. Operating Principles

Corporate Investigator .com will conform with the relevant legislation in force at the time governing the use and monitoring of emails and the Internet, which principally involves: the Human Rights Act 1998, the Data Protection Act 1998, the Regulation of Investigatory Powers Act 2000 and the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699). All practical steps will be taken to inform users about their legal rights under the legislation in force at the time through the communication of this policy.

The Internet facilities, all emails and the systems upon which both are stored and operated are the property of Corporate Investigator .com and are monitored for business and security purposes and to ensure that appropriate use is being made of the systems at all times. Specific acknowledgement will be obtained from users to the fact that email and Internet usage will be monitored - see section 10 below.

The email and Internet system is primarily for business use.

[While it is acceptable to send personal messages to co-employees in appropriate circumstances, e.g. wishing a colleague a happy birthday, suggesting a time for lunch, etc., personal messages should not be sent externally, nor are they permitted to be received. As such, email addresses of employees must not be given to personal relatives, friends, etc. In addition, the Internet is purely for business use and may not be used for personal activities such as shopping, Internet banking, etc.]

Corporate Investigator .com grievance procedures will be available as the vehicle to handle disputes concerning the application of this policy.

Corporate Investigator .Com will provide suitable awareness mechanisms for directors, managers, human resource practitioners and employee representatives in order to ensure full compliance with this policy and an informed approach to its application.

The procedures set out in this policy are designed to minimise the risk of incurring liability in relation to emails and Internet usage. Disciplinary action will be taken against any employee who breaches any of the instructions or operating rules contained in this policy, which will include summary dismissal for those committing acts of gross misconduct.

Any employee who considers that the policy has not been followed in respect of email or Internet usage, the results of which could be llegal in any way, should raise the matter with their immediate superior, or if this would not be appropriate in the circumstances, the managing director. 3.

Some Terms Explained

The 'Internet' is an international network of linked computers. It supports a number of protocols that enable the computers to transfer information between one another. One such protocol is HTTP, the system that allows users to browse the World Wide Web. Most protocols, such as those supporting email, are transparent to the user.

The 'World Wide Web' is simply a collection of web pages. The Internet and the World Wide Web are two distinct but dependent entities.

An 'intranet' is an internal network, similar to the Internet, which is used for communication within an organisation.

'Spamming' is sending large amounts of uninvited email or 'spam' (the electronic equivalent of junk mail).

5. Monitoring

The reserves the right to monitor, at any time, all Internet usage, including Internet browser history files, storage of temporary Internet files and any downloads from an Internet site and emails, including deleted emails, and the systems upon which such emails are stored and circulated. This right is reserved solely for the purpose of monitoring Internet usage or communications for business purposes as set out below.

While an email that is clearly private does not fall within the definition of a communication that is relevant to the    's business, we maintain a right to monitor such a communication where there is a reasonable suspicion that the content breaches the policy, for example, by transmitting trade secrets or pornography.

We exercise the right to intercept emails and Internet access under the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699) ('the Regulations') for the following reasons: to investigate or detect the unauthorised use of the systems, e.g. that this policy is being observed, that no discriminatory or offensive content appears in emails, etc.; to maintain an adequate level of security for our computer systems; to detect any computer viruses; to check mailboxes of absent employees;  

To exercise its right under the Regulations, the must have made all reasonable efforts to inform every person who may use the system that interception may take place. While we believe that the communication of this policy to all employees meets this requirement, we want to be totally open and transparent and will ask each employee to sign a recognition agreement that this policy has been explained to them. As far as external senders of email are concerned, a statement will be included in any automatically generated 'signature' to outgoing emails (see disclaimer at section 12 below).

In exercising its right to monitor emails and Internet usage, the     is conscious of its obligations under the Data Protection Act 1998     [cross-refer to your data protection policy if you have one] as information derived from the interception of communications is covered by the data protection principles. The     will therefore observe the guidelines laid down in Part 3 ("Monitoring at Work") of the Information Commissioner's Employment Practices Code. These are as follows:

We will not monitor the content of email messages unless it is clear the business purpose for which the monitoring is undertaken cannot be achieved by the use of a record of email and Internet access traffic. If the traffic record alone is not sufficient to achieve the business purpose any further monitoring will, as far as possible, be strictly limited and targeted.

We will only conduct detailed monitoring where an impact assessment shows that monitoring is justified, particularly taking account of the privacy of those using the systems, including those sending emails to the    .

Wherever possible, we will avoid opening emails, especially ones that clearly show they are private or personal.

Email monitoring will be confined to address/heading unless it is essential for a valid and defined reason to examine content.

Where reasonable and practicable, and unless this is obvious, ensure that those sending emails to employees, as well as employees themselves, are aware of any monitoring and the purpose behind it.

If it is necessary to check the email accounts or Internet usage details of employees in their absence, make sure that they are aware that this will happen.

We will inform employees of the extent to which information about their Internet access and emails is retained in the system and for how long, i.e. information about Internet access details are retained for     [enter time] and information about emails records are retained for     [enter time].

6. Corporate Image

While emails are a valuable internal messaging tool, they are also sent to external contacts, e.g. customers, suppliers, etc. As with written communications such as letters or faxes, the     needs to ensure that the content and structure of emails reflects a professional image and all emails should follow these guidelines:

All emails should be composed using in     format. Do not use underline, colours, graphics and tables as these may be lost in external emails and may adversely affect delivery times.

Ensure the subject matter is clearly indicated in the heading of emails and maintain a professional image by ensuring that the style and content of emails is appropriate to the subject matter.

Since reading from a screen is more difficult that reading from paper, the structure and layout is very important for email messages. Use short paragraphs and blank lines between each paragraph.

When making points, number them or mark each point as separate to keep the overview.

Identify yourself as the sender at the end of the email and include other contact details, i.e. your telephone and fax number.

Re-read messages prior to sending to ensure accuracy and clarity, and always spell-check emails and attachments before clicking the 'send' button.

A disclaimer will be automatically attached to all emails sent to external contacts as set out in section 11 below.

7. Standard Email Best Practice

Do not use email for urgent messages; use the telephone instead. It should be noted that the delivery and integrity of Internet email messages cannot be guaranteed.

Ensure you have correctly spelled your intended recipient's email address, thus avoiding non-delivery or mail failure error messages. Be careful when using global address lists and personal address lists. Check that only those recipients for whom the mail is intended have been included.

Be concise and to the point. Do not make an email longer than it needs to be. Reading an email is harder than reading printed communications and a long email can be very discouraging to read.

Use correct spelling, grammar and punctuation. This is not only important because incorrect spelling, grammar and punctuation give a bad impression of our     but it is also important for conveying the message properly. Emails with no full stops or commas are difficult to read and can sometimes even change the meaning of the text.

Do not attach unnecessary files. By sending large attachments you can annoy other users and even bring down their email system. When possible try to compress attachments and only send attachments when they are productive. When sending attachments with external emails agree with the recipient the format to be used, e.g. Word, Excel, etc.

Do not overuse the high priority option. If you overuse the high priority option, it will lose its function when you really need it. Moreover, even if a mail has high priority, your message will come across as slightly aggressive if you flag it as 'high priority'.

Do not write in CAPITALS. IF YOU WRITE IN CAPITALS IT SEEMS AS IF YOU ARE SHOUTING. This can be highly annoying and might trigger an unwanted response in the form of a "flame mail". Therefore, try not to send any email text in capitals.

Read and delete emails regularly. Keep your Inbox and Sent folder contents to a minimum. Email messages are just as important as the post.

Answer swiftly. Users send an email because they wish to receive a quick response. Therefore, each email should be replied to within at least 24 hours, and preferably within the same working day. If you are unable to access you email account, e.g. because you are on holiday, make sure you activate the auto-reply facility indicating where the sender can gain further assistance, where necessary. Alternatively, formally authorise a colleague, by email, to have access to your account and set up the necessary access facilities for the period of your absence.

Answer all questions. An email reply must answer all questions, and pre-empt further questions. If you do not answer all the questions in the original email, you will receive further emails regarding the unanswered questions, which will not only waste your time and the other users' time but also cause considerable frustration.

Do not leave out the message thread. When you reply to an email, you must include the original mail in your reply; in other words click Reply, instead of New Mail. Leaving the thread might take a fraction longer in download time, but it will save the recipient much more time and frustration in looking for the related emails in their inbox!

Treat email messages as you would an item of post. Maintain the necessary records.

8. Operating Rules for Email Users

Never access another employee's email account. The only exception is where the employee concerned has given express consent in writing to gain access during that employee's prolonged absence due to holiday, ill health or some other valid reason. Even if such access is granted, never send an email under the original account holder's name. If there is a need to respond in an emergency, the message should be sent from an individual's own account, headed "Sent on behalf of ".

Do not transmit graphical images or signatures either as an attachment or embedded as a signature to an email. These graphical files could easily be copied and applied fraudulently to other documents, e.g. faxes or electronic letterheads, etc.

Do not originate or distribute chain letters or other "junk" ("spam") email. Do not send trivial messages, jokes, gossip or adverts etc. by email. Do not solicit others by email, whether for charitable, personal or business purposes.

Emails must never contain what could be considered as a defamatory statement. For the avoidance of doubt, a defamatory statement is one, whether oral or written and whether of fact or opinion, which tends to damage the reputation of another individual or organisation. Remember that damaging emails may have to be disclosed in litigation or in investigations by other authorities.

Never send an email that contains illegal, discriminatory (on grounds of sex, race, disability, sexual orientation, religion or belief, or indeed any other unacceptable grounds, such as age), obscene, pornographic or otherwise abusive or threatening messages. Harassment or bullying will not be tolerated under any circumstances and in certain circumstances may constitute a criminal offence. Failure to comply with this rule will be considered as gross misconduct.

Employees are prohibited from sending confidential information, or disclosing the Corporate Investigator .Com trade secrets by email. For the avoidance of doubt, confidential information covers items such employee data, customer lists, marketing strategies, pricing information, and so on; trade secrets cover designs, formulae and secret ingredients. In addition, employees must never send 'off the record' emails - nothing is "off the record" where the law requires disclosure of information.

Always file a paper copy of emails in client files for record-keeping purposes. Delivery confirmations cannot be guaranteed as proof of delivery for email messages sent across the Internet.

Beware of viruses and always scan before opening or sending attachments or immediately on receipt of any software or data sources received from an external source. Although software tools are in place to scan all emails for viruses upon entry to the email system, staff are required to take all reasonable steps to guard against viruses being introduced into the Corporate Investigator .Com computer system or the systems of third parties. Intentional introduction of viruses is a criminal offence under the Computer Misuse Act 1990.

Never distribute documents, pictures, music or works of others without the copyright owner's permission. Copying materials which are protected by copyright, without the permission of the copyright owner, is an offence which can give rise to both personal liability and liability on the part of Corporate Investigator .Com.

Do not enter into contractual commitments by email. Communicating by email is so easy and informal, there is a danger that the communicating parties can be lulled into a false sense of security. This might lead them to form contractual obligations without following the set procedures for the formation of contracts.

Employees have a duty to report any breaches of the operating rules set out above which come to their attention. A failure to do so, in itself, will be considered a disciplinary offence as  Corporate Investigator .Com expects reasonable support and co-operation from employees to ensure that any malpractice is unearthed and dealt with.

9. Operating Rules - the Internet

Corporate Investigator .Com has software and systems in place that monitor and record all Internet usage. Our security systems are capable of recording (for each and every user) each World Wide Web site visit and we reserve the right to do so at any time. No employee should have any expectation of privacy as to their Internet usage.

Our managers will review Internet activity and analyse usage patterns and they may choose to publicise this data to assure that the Corporate Investigator .Com Internet resources are devoted to maintaining the highest levels of productivity.

We reserve the right to inspect any and all files stored in private areas of our network in order to assure compliance with policy.

Because a wide variety of materials may be considered offensive by colleagues, customers or suppliers, it is a violation of Corporate Investigator .Com policy to store, view, print or redistribute any document or graphic file that is not directly related to the user's job or the Corporate Investigator .Com business activities.

The downloading and/or display of any kind of sexually explicit image or document or other offensive or obscene material, e.g. racist, homophobic, anti-religious, pornographic, etc., on the Corporate Investigator .Com system that may be capable of constituting any form of discrimination or criminal offence is a violation of our equal opportunity policy. In addition, sexually explicit or other offensive or obscene material may not be archived, stored, distributed, edited or recorded using our network or computing resources. Any such action will be considered as gross misconduct.

The downloading and/or display of any kind of illegal material, e.g. how to make a bomb, on any Corporate Investigator .Com system is prohibited. In addition, such material may not be distributed, edited or recorded using our network or computing resources. Any such action will be considered as gross misconduct.

The Corporate Investigator .Com has installed an Internet firewall to assure the safety and security of the Corporate Investigator .Com networks. We may block access from within our networks to all such sites that we know of. If you find yourself connected accidentally to a site that contains sexually explicit or offensive material or illegal material, you must disconnect from that site immediately.

This    's Internet facilities must not be used to violate the laws and regulations of the United Kingdom or any other nation. Use of any of Corporate Investigator .Com resources for illegal activity is grounds for immediate dismissal and we will cooperate with any legitimate law enforcement activity.

Any software or files downloaded via the Internet into Corporate Investigator .Com network become the property of Corporate Investigator .Com. Any such files or software may be used only in ways that are consistent with their licenses or copyrights.

No employee may use the Corporate Investigator .Com Internet facilities to:

Download or distribute pirated software or data

Propagate any computer virus

Disable or overload any computer system or network

Circumvent any system intended to protect the privacy or security of another user

Any such action will be considered as gross misconduct.

Corporate Investigator .Com retains the copyright to any material posted on the Internet by any employee in the course of his or her duties.

Employees may use their Internet facilities for non-business research or browsing during meal-time or other breaks, or outside of work hours, provided that all other usage policies are adhered to.

Employees must take particular care to understand the copyright, trademark, libel, slander and public speech control laws of all countries in which this Corporate Investigator .Com maintains a business presence, so that our use of the Internet does not inadvertently violate any laws which might be enforceable against us.

Any file that is downloaded must be scanned for viruses before it is run or accessed.

Employees may not use the Corporate Investigator .Com Internet facilities to download entertainment software or games, or to play games against opponents over the Internet.

Employees with Internet access may not use Corporate Investigator .Com Internet facilities to download images or videos unless there is an express business-related use for the material.

Any employee who attempts to disable, defeat or circumvent any of Corporate Investigator .Com security facilities will be subject to summary dismissal for gross misconduct.

10. Responsibilities

Responsibility for overall ownership, communication and monitoring of this policy rests with Corporate Investigator .Com, who will review the policy every six months or as otherwise necessary to ensure compliance with the law and best practice.

Overall responsibility for training people on the use of the email system and Internet system lies with Corporate Investigator .Com, who may delegate responsibility for training to suitably qualified and accredited trainers and which will include training in use of email as part of the induction programme.

Overall responsibility for the strategic development of the email system and Internet system, technological developments and the day-to-day management rests with Corporate Investigator .Com.

Each individual in Corporate Investigator .Com who is an authorised user of the system and/or Internet system is responsible for complying with the rules, procedures, guidelines and good practice statements set out in this policy.

11. Disclaimer - Automatically Attached to Every External Email

The disclaimer reads as follows:

"The contents of this email are confidential to the intended recipient at the email address to which it has been addressed. It may not be disclosed to or used by anyone other than this addressee, nor may it be copied in any way. If received in error, please contact and then delete it from your system. Please note that neither Corporate Investigator .Com nor the sender accepts any responsibility for viruses and it is your responsibility to scan the email and attachments (if any). No contracts may be concluded on behalf of Corporate Investigator .Com by means of email communications.

Please note that Corporate Investigator .Com reserves the right to monitor emails for the purpose of monitoring or communications relevant to the Corporate Investigator .Com business under the Telecommunications (Lawful Business Practice) (Interception Of Communications) Regulations 2000 (SI 2000/2699) ("the Regulations") for the following reasons: to investigate or detect the unauthorised use of the systems, e.g. that this policy is being observed, that no discriminatory or offensive content appears in emails; to maintain an adequate level of security for our computer systems; to detect any computer viruses; to check mailboxes of absent employees;. To exercise its right under the Regulations Corporate Investigator .Com must have made all reasonable efforts to inform every person who may use the system that interception may take place and this notice you be regarded as such notification."

This policy supersedes any other policy on the use of email and the Internet.

 Should you have any questions regarding this Privacy Policy, please contact:

Alexander Moore Managing Director