Updated: October 1, 2018
These guidelines are for law enforcement officials seeking information about SnapSuggest user accounts. When SnapSuggest receives a request for user account information from a government agency investigating criminal activity, the SnapSuggest team reviews each request to be sure that it satisfies all legal requirements. SnapSuggest is committed to cooperating with law enforcement while respecting each individual’s right to privacy.
What is SnapSuggest?
SnapSuggest, an assumed name of Loyalty Grades LLC, a North Carolina limited liability company that develops and maintains a mobile application that automates the suggestion box and adds a social layer to manage the overall process. Users must be employees of a company that is a licensee of SnapSuggest. Users can post suggestions, vote on suggestions, and comment on suggestions. SnapSuggest is available as a mobile app for both iOS and Android.
What Account Information Does SnapSuggest Have?
Suggestions and comments posted on SnapSuggest are public, within each company setting. So, anyone in each company (who is a subscriber) can download the app and see suggestions and comments. SnapSuggest requires users to register, using their company provided email address and a confirmation sent to that address. However, SnapSuggest allows users to mark their suggestions and comments as anonymous. When users mark a suggestion or comment as anonymous, SnapSuggest does not associate a user's name or email with the suggestion or comment. SnapSuggest does not ask its users to provide their real names, mailing addresses, phone numbers, or other such identifying information (beyond their company email email address). SnapSuggest does maintain a log, however, of the following information for each message posted:
- The IP address from which the message was posted;
- The time and date when the message was posted.
Data Retention and Preservation Requests
SnapSuggest retains different types of information for different time periods. Due to the real-time nature of SnapSuggest, some information may be stored for only a very brief period of time.
SnapSuggest will not retain data for law enforcement unless it receives a valid preservation request. Preservation requests must be submitted in writing, on official law enforcement letterhead, and signed by the requesting official. Please include screenshots of the messages that you wish to be preserved, if available. Requests may be sent as an email attachment (our contact information is below).
Legal Process Requirements
SnapSuggest discloses user account information only in accordance with applicable law, including the federal Stored Communications Act (“SCA”), 18 U.S.C. § 2701 et seq. SnapSuggest will only release non-public information about its users to law enforcement officials, and only in response to appropriate legal process, such as a subpoena, court order, or search warrant – or in response to a valid emergency request, as described below. Under the SCA:
- A valid administrative, grand jury, or trial subpoena in connection with an official criminal investigation or prosecution is required to compel SnapSuggest to disclose certain specific types of “basic subscriber information” (defined in 18 U.S.C. § 2703(c)(2)). However, because SnapSuggest provides an anonymous service SnapSuggest’s records of “basic subscriber information,” if any, are likely to be very limited.
- A court order issued under 18 U.S.C. § 2703(d) is required to compel SnapSuggest to disclose certain non-content records associated with a user’s account. This could include the time and date when a message was posted and the IP address associated with the message.
- A search warrant is required to compel SnapSuggest to disclose the contents of any messages associated with a user’s account.
Under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4), SnapSuggest may disclose user account information to law enforcement – without a subpoena, court order, or search warrant – in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone (for instance, in cases involving kidnapping, bomb threats, school shootings, or suicide threats). SnapSuggest evaluates emergency requests on a case-by-case basis.
Any information SnapSuggest provides in response to emergency requests is limited to what we believe would prevent the harm. This may include a user’s IP address, message timestamps, and/or the contents of other messages from the user’s posting history.
Law enforcement officers can submit an emergency request as an email attachment (our contact information is below). Emergency requests must be submitted on law enforcement letterhead, and must include the following:
- a detailed description of the emergency;
- a description of the harm to be prevented;
- a detailed description of the SnapSuggest post that you are seeking information about, including screenshots, if available;
- the specific information requested, including an explanation of why that information is necessary to prevent the harm;
- an explanation of why the information is needed without waiting for legal process;
- and the signature of the submitting law enforcement officer.
Please note that SnapSuggest cannot review or respond to emergency requests sent by non-law enforcement officials. If you are aware of an emergency situation, you should immediately contact your local law enforcement officials.
Will SnapSuggest Notify Users About Law Enforcement Requests?
SnapSuggest does not have email addresses or other contact information for users who make anonymous posts. Therefore, SnapSuggest is unable to notify the user when it receives a request from law enforcement seeking account information for anonymous posts. For non-anonymous posts, SnapSuggest will make our best effort to notify the user if possible.
Law enforcement officials may submit requests by mail or email to:
514 Daniels Street, Suite 353
Raleigh, NC 27605
Receipt of correspondence by any of these means is for convenience only and does not waive any objections, including the lack of jurisdiction or proper service. SnapSuggest will not respond to requests for user information sent by non-law enforcement officials.