CivicPlus Subpoena Response Policy

Effective Date: November 4, 2024

At CivicPlus, we prioritize the privacy and security of our customers’ and end user’s data. As a data processor and custodian for our customers, we are committed to handling all legal requests, including subpoenas, with transparency and in full compliance with applicable laws. This CivicPlus Subpoena Response Policy is an overview of how we compliantly handle subpoenas and protect our customers' and end users’ data when we receive such requests.

Customer-Owned Data

Per our customer agreements, the majority of the data we process belongs to our customers. If a customer has full ownership and access to the requested data, CivicPlus will direct all informal and formal requests received for that information to the data-owning customer. We encourage requestors to contact the customer directly to obtain the data.

However, if the requested data is only accessible and held by CivicPlus, such as in certain data logs or other internal records that are not available to the customer, a formal legal request is required before CivicPlus can provide the data. In order to protect the integrity and trust of our customer solutions, CivicPlus requires all parties, including its customers, to submit a subpoena when requesting data only accessible and held by CivicPlus.

Notwithstanding the foregoing, if we believe, in our sole discretion, that the disclosure of data held by CivicPlus is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, CivicPlus may disclose such information without a court order, subpoena, or other legal process requiring such disclosure.

Submitting a Formal Request

If you are requesting data that the customer cannot access, such as internal logs or technical records only available to CivicPlus, a formal and valid subpoena must be submitted. This subpoena should be addressed to the “custodian of records” and sent to CivicPlus’s legal team and the following email address:

CivicPlus, LLC

Attention: Legal Department

302 S 4th Street, STE 500

Manhattan, KS 66502

with a copy to:

CivicPlus Legal Email

Notification to Customers

CivicPlus will respond to valid subpoenas as required by law. When we receive a subpoena from a third party for data related to one of our customer’s services, we promptly notify the affected customer, unless we are legally prohibited from doing so. This allows our customers to be informed of the request and, if necessary, to respond or contest it. Further, CivicPlus will provide all responses to a subpoena to the data-owning customer.

Legal Review

Each subpoena undergoes a thorough legal review to ensure its validity and compliance with relevant legal requirements. We verify the authority of the issuing party and review the scope of the data requested. If the subpoena is overly broad, burdensome, or unlawful, we reserve the right to challenge or object to providing the information requested in the subpoena.

Data Minimization

CivicPlus follows a data minimization policy when responding to subpoenas. This means we only disclose the minimum amount of information necessary to comply with the legal request. Our goal is to limit exposure and ensure that any data provided is directly relevant to the request. CivicPlus reserves the right to challenge any subpoena for reasons including, without limitation, whether the data request in the subpoena is overly broad or requests irrelevant data.

Secure Data Handling

If a subpoena is valid and uncontested, we prepare the requested data for disclosure in a secure and controlled manner, ensuring that only the data specified in the subpoena is shared. Unless specifically prohibited by law, CivicPlus will share the comprehensive data disclosure for the subpoena response with the affected customer at the time of response to the subpoena.

Documentation and Record-Keeping

For each subpoena, we maintain detailed records of the request, the data disclosed, and communications with the requestor and customer. This ensures full transparency and compliance with our legal obligations.