Privacy Notice
1. About This Privacy Notice
James Rae Investigations respects your privacy and is committed to handling personal information lawfully, fairly and responsibly.
This Privacy Notice explains how we collect, use, store and share personal information when you:
visit our website;
contact us or submit an enquiry;
become a client;
correspond with us;
are connected with an investigation or enquiry; or
are a person whose information is lawfully identified during investigative, open-source or analytical work.
James Rae Investigations provides private investigation, open-source intelligence (OSINT), digital research and analytical services using principally publicly available and lawfully accessible information, together with information lawfully supplied by clients.
2. Who Is Responsible for Your Information?
James Rae Investigations is responsible for determining how and why personal information is processed in connection with the services described in this Privacy Notice.
For data-protection purposes, James Rae Investigations acts as the data controller where it determines the purposes and means of processing personal information.
You can contact us at:
James Rae Investigations
Email: james@jamesraeinvestigations.co.uk
Our ICO registration details will be added to this Privacy Notice once registration has been completed.
3. Personal Information We May Collect
The information we collect depends on your relationship with us and the nature of the enquiry or investigation.
Clients and People Making Enquiries
We may collect:
your name;
email address;
telephone number, where provided;
preferred method of contact;
information contained in your enquiry;
details of what you would like to establish;
information about your relationship to the matter;
information and documents you choose to provide;
correspondence between you and James Rae Investigations;
information required to assess whether an instruction can appropriately be accepted;
agreed investigation scope and instructions;
invoicing and payment information; and
other information reasonably necessary to provide or administer our services.
Please avoid providing personal information that is not relevant or reasonably necessary to your enquiry.
Investigation Subjects and Other Individuals
During legitimate investigative or analytical work, we may identify or process information including:
names;
usernames, aliases and online identifiers;
publicly available social-media information;
publicly available photographs or images;
websites and webpages;
digital footprints and online activity;
publicly available professional or employment information;
business and company information;
directorships and other publicly recorded business relationships;
publicly available contact or location information where relevant;
online relationships or associations where reasonably and lawfully identified;
news and media information;
archived online material;
information contained in public registers and other public sources;
information lawfully supplied by a client; and
other publicly available or lawfully accessible information relevant to the agreed investigative purpose.
We aim to collect and use information that is relevant, necessary and proportionate to the legitimate purpose of an investigation rather than collecting information simply because it is available.
If you have any questions about this Privacy Notice, please contact James Rae at james@jamesraeinvestigations.co.uk.
4. Where We Obtain Personal Information
Personal information may be obtained from:
you directly;
clients who instruct us;
information and documents lawfully supplied to us;
publicly accessible websites;
publicly accessible social-media profiles and content;
search engines;
publicly available company and director information;
public registers and official sources;
news and media publications;
web archives;
publicly available professional information; and
other lawful open-source intelligence sources.
Information being publicly available does not mean that it falls outside data-protection law. We still consider whether its collection and use is necessary, relevant and proportionate.
5. Why We Use Personal Information
We may process personal information to:
receive and respond to enquiries;
assess whether an investigation should be accepted;
establish whether there is a legitimate purpose for proposed investigative work;
communicate with clients and prospective clients;
prepare quotations and agree investigation scopes;
enter into and perform contracts for investigative services;
undertake agreed investigations, research and analysis;
conduct lawful open-source intelligence research;
identify, verify and cross-reference relevant information;
investigate online identities and digital footprints;
undertake lawful people-tracing enquiries;
conduct background and due-diligence research;
analyse communications, documents and digital information supplied to us;
identify timelines, patterns, relationships, associations and inconsistencies;
prepare reports, assessments, chronologies and other agreed deliverables;
maintain appropriate case and business records;
administer invoices and payments;
maintain the security and integrity of our website and systems;
prevent or respond to misuse of our services;
handle complaints;
comply with applicable legal and regulatory obligations; and
establish, exercise or defend legal claims.
6. Our Lawful Bases for Processing
Data-protection law requires us to have a lawful basis for processing personal information. The appropriate basis depends on the circumstances.
Contract
We may process information where it is necessary:
to take steps at your request before entering into a contract; or
to perform a contract for investigative services with you.
For example, we may need to process your contact details, instructions and information about your enquiry to assess and provide the service you have requested.
Legitimate Interests
We may process personal information where this is necessary for legitimate interests pursued by James Rae Investigations, a client or another person, provided those interests are not overridden by the rights and freedoms of the individual concerned.
Depending on the circumstances, legitimate interests may include:
establishing or verifying relevant facts;
conducting legitimate and proportionate investigative research;
investigating potentially misleading or false online identities;
locating individuals for legitimate purposes;
undertaking appropriate background research or due diligence;
protecting legitimate personal, legal or commercial interests;
analysing information relevant to a legitimate dispute or concern;
preventing misuse of our services;
maintaining the security and effective operation of our business; and
establishing, exercise or defend legal claims.
Legitimate interests are not treated as an automatic justification for an investigation. Where appropriate, we consider the purpose of the processing, whether using the information is necessary and whether the individual's interests, rights and freedoms override the identified legitimate interest.
We may decline or restrict an investigation where we consider that the proposed processing would be inappropriate, unnecessary, disproportionate or unlawful.
The ICO requires organisations relying on legitimate interests to consider the purpose, necessity and balancing tests and to explain the legitimate interests involved.
Legal Obligation
We may process personal information where necessary to comply with a legal obligation that applies to us.
Consent
We may rely on consent where this is the appropriate lawful basis for a particular activity. Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
We do not rely on consent merely because information about an investigation subject is publicly available.
We process personal information under several lawful bases, including the performance of a contract, compliance with legal obligations, and the pursuit of legitimate interests (such as conducting lawful investigations for clients).
7. Special Category and Criminal Offence Information
Our services are not designed around obtaining private medical records, police records or other restricted records. However, publicly available material or information lawfully supplied in connection with an enquiry may sometimes contain particularly sensitive personal information. Where special category personal information or criminal offence information is encountered, we will consider whether it is necessary and appropriate to process it and whether the additional conditions required by data-protection law are satisfied. We will not deliberately collect or retain sensitive information simply because it is available. Where there is no appropriate lawful basis and applicable additional condition for processing such information, it will not be used for the investigative purpose.
8. Investigation Subjects and Information Obtained Indirectly
Some investigations necessarily involve processing personal information about people who have not contacted James Rae Investigations themselves. This may occur, for example, during identity investigations, tracing, due diligence, or analysis of relationships. Where information has not been obtained directly, we consider our transparency obligations. The UK GDPR ordinarily requires privacy information to be provided within time limits, unless an exception applies (e.g. impossible or disproportionate effort). Where required, privacy information will be provided. Publishing this Privacy Notice help make practices accessible, but does not replace individual notification where the law requires it.
9. Legitimate-Purpose Screening
We assess enquiries before accepting investigative work. We will not knowingly provide services intended to facilitate stalking, harassment, intimidation, coercive behaviour, unlawful discrimination, or unauthorised access. We may ask a prospective client to explain their relationship to the matter. An instruction may be declined where we are not satisfied that the investigation is legitimate, necessary and appropriate.
10. Accuracy and Limitations of Open-Source Information
Information found online or in public sources may be inaccurate, incomplete, outdated or relate to another person. Where practicable, we seek to cross-reference information and distinguish between corroborated facts, indications, inconsistencies and matters that cannot be established. The existence of information online does not necessarily mean that it is accurate.
11. Who We May Share Personal Information With
We do not sell personal information. Where necessary, information may be shared with the client who commissioned the work, technology service providers, payment providers, professional advisers, or required authorities. We seek to limit disclosures to relevant and necessary information. Clients receiving information may have their own responsibilities under data-protection laws.
12. International Transfers
Some technology or service providers used in operating our website, communications or business systems may process information outside the United Kingdom. Where transferred internationally, we will take reasonable steps to ensure that an appropriate lawful transfer mechanism or safeguard is in place where required by UK law.
13. How Long We Keep Personal Information
James Rae Investigations does not retain investigative information indefinitely. Files will be deleted as soon as they are no longer required. Material will ordinarily be retained for no longer than six months after an investigation is closed, unless a specific valid reason exists. Certain limited business records (e.g. invoices) may be retained for longer to meet legal requirements.
14. Security
We take reasonable organisational and technical measures designed to protect personal information against unauthorised access, disclosure, or accidental loss. Access to investigation material is limited to those who reasonably require it for the relevant purpose. While no storage or communication is completely secure, steps are taken to protect information based on its nature and risks.
15. Website and Cookies
When you visit our website, certain technical information may be processed. The website is built using Wix and uses Usercentrics for Wix to manage cookie consent. For further information about cookies, including how to manage your preferences, please see our Cookie Policy. Consent choices can be managed through the controls provided on the website.
16. Do You Have to Provide Personal Information?
You are not generally under a statutory obligation to provide personal information simply because you contact us. However, certain information may be necessary for us to assess your enquiry, provide quotations, enter into contracts, or perform investigations. If necessary information is not provided, we may be unable to accept the instruction.
17. Automated Decision-Making and Profiling
James Rae Investigations does not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects. Investigative findings and analytical conclusions involve human review and assessment.
18. Your Data Protection Rights
Depending on the circumstances, you may have rights including access, rectification, erasure, restriction, objection, or portability. These rights are not absolute and depend on the situation and exemptions. Contact james@jamesraeinvestigations.co.uk to exercise your rights.
IMPORTANT — YOUR RIGHT TO OBJECT
Where we process based on legitimate interests, you have the right to object. If you object, we will consider your request and the circumstances of the processing. Where required by law, we will stop processing your information unless there are compelling legitimate grounds for continuing which override your interests, rights and freedoms, or the processing is required for the establishment, exercise or defence of legal claims. You can make an objection via the email above. The ICO requires this right to be highlighted clearly.
19. Requests Concerning Investigation Information
A request to exercise a data-protection right does not automatically mean that all information connected with an investigation must be disclosed, changed or deleted. Data-protection rights may be subject to exemptions or restrictions under applicable law. Each request will be considered on its individual circumstances.
20. Complaints About Personal Information
If you have concerns, please contact us at james@jamesraeinvestigations.co.uk in the first instance. You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent regulator.
21. Changes to This Privacy Notice
We may update this Privacy Notice where services, activities, or legal requirements change. The latest version will be published on this website and the Last updated date will be amended where appropriate.
22. Contact Us
For questions about this Privacy Notice, how we process personal information or to exercise a data-protection right, contact: James Rae Investigations Email:Â james@jamesraeinvestigations.co.uk