Government requests

We review the legality of every request

No data leaves in response to a request until the responsible person has checked, in writing:

• Who is asking. The requesting body, the named officer, and a contact route we verify independently rather than one supplied in the request. A request arriving by email from an unverifiable address is treated as suspect until proven otherwise, because impersonating an authority is a known method of extracting data.
• Under what power. The specific statute, warrant, subpoena or court order relied on. Assisting an investigation is not a legal basis.
• Whether it binds us. Whether the authority has jurisdiction over our entity, and whether the instrument is one we are actually compelled to answer.
• Whether we hold it at all.In most cases the data belongs to a customer's business rather than to us. Where a request is properly directed at them, we say so and, unless legally barred, tell that customer so they can respond themselves.

An informal or voluntary request is refused by default. We answer compelled requests, not helpful ones.

We will challenge a request we consider unlawful

If the review finds a request overbroad, unfounded, outside jurisdiction, or seeking data we should not hand over, we do not comply while we contest it. In practice that means responding in writing with the objection and asking the authority to narrow or withdraw it, taking external legal advice where the request is significant or the objection is contested, and, where a lawful order stands after challenge, complying with that order and no further.

We would rather be late and correct than fast and wrong. A deadline stated in a request is not a reason to skip this.

We disclose the minimum necessary

A request for one person's data is answered with that person's data, for the period specified, and nothing else. No bulk export because it is easier than filtering. No adjacent records, no other people in the same thread, no whole workspace. Where a request can be satisfied with less, such as a date range rather than an account history, we provide the less.

Access tokens, secrets and credentials are never disclosed. They authenticate us to a platform and are not evidence about anyone.

We document every request

Each request is recorded, whether or not we comply, and kept for at least seven years. The record holds the request and the date it arrived, the authority and named officer, the legal instrument relied on, the legality review and its reasoning, what we disclosed or the grounds on which we refused, who inside Parlow decided and who else was involved, and whether the affected customer was notified along with the legal reason if they were not.

The point of the log is that we can answer a question about a request years later from the record rather than from memory.

Notification

Unless a court order or statute forbids it, we tell the affected customer before disclosing anything about them or their end users, so they have the opportunity to object. Where we are barred from notifying immediately, we notify as soon as the prohibition lapses.

Contact

Requests should be sent in writing to:

See also our privacy policy, which sets out what data we hold and how it can be deleted.