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ICI Corporate Philosophy and Policy On Privacy and Proactive Governmental Regulatory Action

Times are changing and our only option is to accept those things that we cannot change, change the things that we can and try to figure out the difference between the two.

In the United States, privacy special interests have exploded onto the national scene. They often bring into the public debate socially responsible commentary. However, they rarely tell the full story. In weighing the public's right-to-know against the privacy interests of a few, ask yourself:

• By walling off access to certain financial and banking information, who will pay the cost associated with frauds upon these institutions?
• Where do you tell your client to go to pick up their check for restitution because of a failed investment that was not properly probed?
• How will local governments generate additional revenue when they can no longer sell public records?
• How will parents be assured of their child's safety from unchecked teachers, bus drivers, and home care providers?

The issues here are very complex and stir great passion. The privacy lobby became a powerful special interest group because of the excesses of only a few; the remainder of the responsible members of the industry will pay the price.

On one hand, the explosion of the Internet and e-commerce is a compelling vehicle to deliver all sorts of information on the people we wish to know about, the places that we seek to investigate, and the things that we seek to check out.

The reality is that the private investigations industry, information brokers, private intelligence analysts, etc., are all scrambling to obtain a "cut of the pie" and roll out their services, products and capabilities through the Internet - an open and public forum.

Therefore, all searches ordered by our clients must conform to local, state and federal laws. The laws are not uniform. They are confusing. And they are constantly changing. Legal pundits have opined that some of these laws are so confusing that they are unconstitutional.

We leave the legal arguments to learned counsel, ICI expresses no opinion about the regulatory community generally or the privacy interests specifically, other than to state that we accept them and abide by each to the best of our ability.

It is the responsibility of our clients to ensure that each search complies with all applicable laws. We accept no responsibility for investigating the many local, state and federal laws that might apply or for determining compliance.

For our part, corporate policy is as follows:

• ICI will provide services only to licensed attorneys or law firms and general counsels of multinationals.
  
  
• ICI will not offer any services or accept any assignments from any member of the general public that is not represented by counsel.
  
  
• Will only deliver its reports by messenger, FedEx or encrypted e-mail to a licensed attorney, although fees may be paid by the ultimate client after approved by counsel.
  
  
• ICI will not have any contact with the ultimate client without the physical or telephonic presence of counsel.
  
  
• ICI vets the background of all clients to make certain that they are properly licensed to practice law in the courts of their home jurisdiction.
  
  
• ICI will not cite any price for services or products on the open Internet.
  
  
• ICI will not allow any World Wide Web or HTTP address on its Web Site that permits visitors to link to a search site. All hyperlinks are contained in a Restricted Access Hyperlink Library that is constantly vetted by ICI analysts for relevance, operational security, and use by attorneys.
  
  
• ICI will handle no case involving child pornography, child abuse, or child victim investigations or prosecutions.
  
  
• Will not provide services to any local, state or federal governmental agency of any kind.
  
  
• ICI will not identify its clients, unless and until ordered by a court of competent jurisdiction.
  
  
• In all matters, ICI will rely on the attorney-client privilege, the attorney work-product doctrine, and any other applicable privileges to prevent intentional disclosure of our work-product, which is not our property, but is specifically titled to counsel. ICI acts only as an agent for its clients in an effort to obtain information through lawful means.
  
  
• ICI will not advertise our services or products in any magazine, periodical, newspaper, television commercial, or seek to obtain business from the general public. Our Internet site is intended only for attorneys and is informational in nature and is not to be construed as a solicitation.

The client is urged to carefully read our TERMS AND CONDITIONS as you are solely and completely responsible for compliance and certification of whatever local, state, federal or international laws that may affect your jurisdiction. ICI expressly disclaims any and all liability, warranty, or duty to conduct legal research or express an opinion as to whether the client's requests comply with said laws.