In addition to conducting interviews, there is a number of other potentially significant sources of information to consider and possibly review as part of an internal investigation. A record of all sources of information reviewed should be retained as part of the investigation file, regardless of whether such information supports, refutes, or sheds no light on the allegations.
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Item |
Relevant/Not |
|---|---|
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□ Company code of conduct, compliance policies and procedures | |
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□ Company records retention policy: Consider whether issuance of an investigational hold is recommended to ensure relevant records are retained and not destroyed. | |
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□ Company records (e.g., hard copy or electronic files, including presentations, memos, calendar and diary entries, notes, emails, instant messages, text messages, messaging apps, phone records): Consider imaging of relevant laptops, but be wary of chain-of-command and privacy issues and consult with legal counsel. | |
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□ Geolocation data from company cell phones or mobile hot spots or other devices: Be wary of potential privacy issues, consult with legal counsel. | |
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□ Employee expense reports and employee’s company credit card statements. | |
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□ Websites, internet, and social media (e.g., Google, Yahoo, Facebook, Twitter, LinkedIn): Be wary of potential privacy issues, consult with legal counsel. | |
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□ Criminal background checks: Be wary of potential privacy issues, consult with legal counsel. | |
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□ Civil/criminal matter background checks: Be wary of potential privacy issues, consult with legal counsel. | |
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□ Company or location video surveillance: Be wary of potential privacy issues, consult with legal counsel. | |
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□ Employee attendance and badge entry/exit records. | |
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□ Employee personnel files or other relevant files (e.g., I-9, worker’s compensation, manager files): Be wary of potential privacy issues, consult with legal counsel. | |
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□ Pictures/video/audio captured on employee cell phones or other recordings available: Be wary of potential privacy issues, consult with legal counsel. | |
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□ Public records | |
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□ Other |