Government Request Log

This document describes how we receive, validate, log, respond to, and report government and court requests (Government & Law Enforcement Requests: GLER) transparently and lawfully, including data scope limitation, user rights, and metrics publication.

1) Scope and Purpose

Covers requests from government, courts, and law enforcement in all jurisdictions for account data, content, or actions on Tanqory services, for merchants, developers, users, and relevant personnel. Goals: protect security, respect privacy rights, comply with law, and provide transparency to the public and partners. Applies to all intake channels (official email, request portals, MLAT) and to data stored by Tanqory or processed by relevant processors. Read with Privacy Policy, DPA, Incident Response Playbook, and Annual Transparency Report.

2) Governance and Roles

Legal owns intake/response, coordinating with Security/Privacy/DPO/Trust & Safety for personal data or high‑risk matters. All requests are logged in controlled ticketing with audit trails. Senior leadership receives summaries at least annually; the Transparency Working Group reviews trends/risks quarterly. Staff handling requests must be trained annually on data protection and state response practices; violations are subject to disciplinary/contractual action. If EU Digital Services Act (DSA) applies to a service, we will maintain designated points of contact for Member States/Commission (Art.11), and a legal representative where required (Art.13). Orders to act against illegal content (Art.9) or to provide information (Art.10) will be verified, recorded, and actioned via secure channels with reason statements and appeal/complaint routes where applicable. Platform‑to‑Business (P2B) requirements for reason statements and complaint handling (Art.11–12 P2B) are honored for affected merchants.

3) Intake and Validation

Requests must be written, legally authorized, jurisdiction‑clear, and narrowly scoped. We verify warrants/orders, agency identity, official channel, and data scope. Incomplete or privacy‑conflicting requests are amended or refused. Gag orders are honored per local law. If jurisdiction is unclear, we seek MLAT or lawful pathways. Data is transmitted only via secure/encrypted channels agreed with the agency. We reject or seek clarification where: (a) the request conflicts with data protection/sanctions/human rights obligations; (b) scope is overbroad; (c) the requester lacks authority or proper service; (d) the request seeks real‑time interception without a lawful basis. Escalation to senior Legal/Privacy occurs for novel or extra‑territorial demands. We keep a decision log (granted/denied/clarified) with legal rationale.

4) Scope Limitation and Privacy

We provide only what is legally necessary (data minimization) and reject overbroad demands. Personal data is redacted/anonymized where permissible. No backdoors or end‑to‑end decryption except where law and competent courts explicitly require. Cross‑border transfers use lawful mechanisms (SCC/Addendum/MLAT) with encryption in transit/at rest. Delivery and accountability are recorded for later audit. If requests involve children/minors or protected/vulnerable groups, stricter review applies and Child Safety Policy/Online Safety obligations are consulted before disclosure. For high‑risk jurisdictions or sanctioned entities, we perform a sanctions/export/human‑rights check and may refuse cooperation consistent with international obligations.

5) User Notice and Appeals

We aim to notify users/merchants before disclosure where law/orders allow, via recorded channels (email/dashboard), with time to appeal/contest. If gagged, we record legal basis and revisit when lifted. Users may ask if their account was requested (where permitted) and may appeal via legal@tanqory.com or stated channels. Notices/appeals and outcomes are logged for transparency. We set internal SLAs for notice (e.g., attempt notice within 5 business days of lawful ability) and for responding to user inquiries about GLER, subject to legal constraints. Templates include the nature of the request, data categories sought, and any available redress. For DSA contexts, reason statements follow Art.17–20 formats where applicable.

6) Logging and Metrics

Each request is logged with metadata: country/agency/type (account data/traffic/content/account action), receipt date, status (granted/denied/clarified), response time, delivery channel, and number of accounts/items affected. Metrics are aggregated for the Annual Transparency Report or dashboards without personal identifiers. Incomplete/unauthorized requests are logged separately to reflect denials/clarifications. Standard open‑data schema (where feasible) includes: country, authority type, legal basis, request category, granted/denied/partial, user notice (yes/no/gagged), response time bands, and appeal stats. Data may be published in CSV/JSON alongside human‑readable reports for year‑over‑year comparison, subject to security/legal constraints.

7) Coordination with Authorities and MLAT

We encourage official and MLAT channels for cross‑border requests to ensure legal footing. If a foreign request lacks domestic legal basis where we operate, we may refuse or require an order from a competent local court. We do not cooperate with requests that violate human rights or sanctions/export controls. Preservation requests are assessed under data protection laws and retention timelines. Preservation orders are time‑bound; we confirm scope and retention window, and do not expand to content not specified. For repeat or bulk requests, we may require batched MLAT processes or court oversight to prevent informal “voluntary” disclosures that bypass due process.

8) Data Security and Chain of Custody

Transfers use encrypted email/secure file channels or verified two‑factor methods. Chain of custody (collector/reviewer/sender/recipient) with timestamps and file hash/integrity checks is recorded. Prepared data is retained only as necessary, then deleted/anonymized. Access to prepared datasets is logged for audit. Retention of GLER records: we keep request logs, legal analysis, notices, and delivery receipts for at least the statutory limitation period or as required by applicable law/regulator; then minimize/delete per retention policy. Chain‑of‑custody records are protected from tampering and included in audit scope.

9) Regional Requirements

EU/UK: follow GDPR/UK GDPR, ePrivacy/PECR, proportionality/necessity; use MLAT/local court orders. US: comply with applicable federal/state law; foreign requests assessed under SCA/MLAT. SG/AU/CA/JP/UAE: adapt to local data protection/court processes. If jurisdictions impose extra reporting (e.g., DSA/DMA/Online Safety, new US state laws), we add sub‑metrics/channels per implementing rules when effective. Brazil (LGPD): ensure legal hypothesis and, where possible, notify data subjects unless barred. India (DPDP): comply with lawful requests under the Act and any sectoral rules; scrutinize extra‑territorial demands. China (PIPL/DSL): if applicable, require security assessments and localization compliance; avoid cross‑border transfers without approvals. Saudi/MEA: consider data localization mandates and regulator approvals. We localize process, notice, and appeal handling to statutory timelines (e.g., DSA reports within one month unless extended). For online safety regimes (e.g., UK OSA), we expedite child‑related illegal content orders.

DSA hosting/online platform duties (if applicable):

• Provide clear notice of restrictions/removals with reasons and appeal options (Art.17–20).
• Maintain internal complaint handling; offer out‑of‑court dispute settlement providers if required.
• For VLOP/VLOSE status, include GLER and illegal‑content order statistics in the DSA transparency report and undergo independent audits.
• Maintain a single point of contact for authorities and a mechanism for trusted flaggers (if designated).

10) Publication and Updates

Statistics are published in the Annual Transparency Report or relevant dashboards. Aggregated counts of government requests are published in the Annual Transparency Report at transparency/annual-transparency-report.md. EU DSA Article 9 orders are flagged separately in line with the DSA Article 24 metrics framework. Material process changes or new laws trigger updates with version/date and notice via dashboard/email (durable medium). If conflicts with Order Form/Addendum or mandatory law, the specific document/law prevails. English is the legal reference; if any part is invalid, the remainder stays effective. We announce planned publication dates of GLER statistics and, where required by law (e.g., DSA), publish in machine‑readable formats. If an error or over‑disclosure occurs, we follow incident response: notify affected parties/authorities where legally required, remediate, and adjust controls. User/merchant inquiries about GLER are handled per defined SLAs and logged.

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