Law Enforcement Liaison

Media.com regularly interacts with public sector agencies, including law enforcement, intelligence agencies, regulators, and other government entities. The Law Enforcement Liaison Policy outlines the principles governing these interactions. This procedure specifically delineates the methods and practices Media.com employs to implement this policy effectively within the organization.

Trust and Safety roles and responsibilities relevant to this procedure are contained in the following table.

When liaising with public sector agencies, Media.com staff are to apply the following principles:

1. Making it a priority to prevent and stop criminal activity, particularly activity causing any form of harm to individual users, stakeholders, groups and the organization.
2. 2. Employing ethical and accountable decision-making and record keeping.
3. Creating a culture of clear and effective internal communications, both vertically and horizontally, when matters are actioned.

In the normal course of business, Requests for Information (RFI) are to be received electronically via the Law Enforcement Response Team (LERT) shared mailbox ([email protected]). RFI received elsewhere in the organization are to be forwarded to the LERT mailbox. RFI may take the form of:

1.  Formal requests for information or assistance
2. Emergency requests
3. Preservation requests
4. Legal requests from official government agencies by way of subpoena, court order or warrant.
5. Requests from official government agencies under Mutual Legal Assistance Treaties (MLAT) or similar international legal processes 

Actioning RFI is the responsibility of the LERT.

Reasonable steps should be taken to ensure the identity and veracity of the RFI to identify RFI  that are suspicious, unverifiable, or from sanctioned jurisdictions. Such RFI should be referred to the Director of Public Sector Relations.

Upon receipt of a RFI, the LERT will triage the RFI to determine its:

1. Validity 
2. Relevant jurisdiction
3. Category (Category 1 or 2)

Category 1 RFI are those that may be sufficiently serious, sensitive or likely to become public in an impactful way, particularly those causing any form of harm to individual users, stakeholders, groups and/or the organization; and, those likely to require a coordinated response or expected to have significant media attention.

Category 2 RFI are those that can be described as routine, or “business as usual requests,” that can be assessed and actioned within the public sector relations team without significant assistance.

Where a RFI is determined to be a category 1 RFI, the LERT is to notify:

1. Director ofPublic Sector Relations;
2. Head of Trust and Safety;
3. Head of Communications and,

Any other departments relevant to the specific matter.

The question of jurisdiction is both complex and fundamental to any incoming RFI to Media.com.

Potential indicators of jurisdiction may include:

• The jurisdiction of the requesting authority
• In the case of a legal document, the jurisdiction of the authorizing court or tribunal
• Internet Protocol (IP) addresses related to the relevant material or account
• The place of residence or business of any involved party

Upon receiving an RFI, LERT is to determine the jurisdiction relating to the RFI.

RFI related to third party civil proceedings are to be referred to Media.com legal.

Staff may detect criminal activity occurring on or through the Media.com platform, such as:

• Hate speech or terrorism
• Cyberbullying and harassment
• Fraud and scams
• Youth safety violations
• Attempted or actual fraud during account creation

All actual or suspected criminal activity should be reported to the LELO.  The LELO is to determine:

• Whether a criminal activity is suspected or known to have occurred.
• The relevant jurisdiction in which the (alleged) activity occurred.
• An assessment of any obligation to report the activity to law enforcement or other agency.

In ambiguous cases, or where the criminal threshold is not clear, advice should be sought from legal counsel as to the requirement to undertake this procedure.

The LELO is responsible for discharging any reporting obligation that arises.  The authorizing authority for reporting is the Director ofPublic Sector Relations.

Account holder (customer) data should not be disclosed to any party, unless the requesting agency has complied with the relevant laws and regulations in both its own and Media dot com Inc’s jurisdiction.

LERT is responsible for gathering data to comply with RFI. Authority for release of customer data in response to RFI is:

• Category 1 RFI - Head of Trust and Safety
• Category 2 RFI - Director - Public Sector Relations

The relevant information should be transferred to the requesting official government agency by 'safe hand' physical transfer or through an approved secure network upon approval. In all cases, this transfer should be recorded in a verifiable manner and recorded as such.