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Aventora Government and Public Authority Data Request Policy

FieldValue
Document NameGovernment and Public Authority Data Request Policy
Version1.0
Effective DateJuly 6, 2026
Approval DateJuly 6, 2026
Last ReviewedJuly 6, 2026
Document OwnerAventora Security
Review FrequencyAnnually; immediately upon material legal or regulatory changes
ClassificationInternal / Customer Shareable

Document Control​

This policy establishes Aventora Inc. (“Aventora,” “we,” “us,” or “our”) requirements for receiving, evaluating, and responding to requests for access to customer data from courts, regulators, law enforcement agencies, national security authorities, and other public authorities.

This document is intended for enterprise customers, security assessors, privacy officers, procurement teams, and Aventora personnel. It supports security and privacy reviews and describes how Aventora protects customer data while responding to lawful requests in a controlled and transparent manner. Aventora does not claim formal certification or attestation under any specific privacy or security framework based on this document alone. Implementation details may vary by deployment model, contractual terms, and applicable law.

RFC 2119 Terminology​

The key words “MUST,” “MUST NOT,” “REQUIRED,” “SHALL,” “SHALL NOT,” “SHOULD,” “SHOULD NOT,” “RECOMMENDED,” “MAY,” and “OPTIONAL” in this document are to be interpreted as described in RFC 2119.

Approval​

RoleNameSignatureDate
Chief Executive Officer[To be completed upon formal approval]
Document Owner (Aventora Security)[To be completed upon formal approval]
Privacy Officer[To be completed upon formal approval]

This policy is effective upon signature by the Document Owner and notification to affected personnel. Material revisions require re-approval and updated version history.

Table of Contents​

  1. Purpose
  2. Scope
  3. Guiding Principles
  4. Types of Requests
  5. Verification Process
  6. Customer Notification
  7. Data Disclosure
  8. Request Log
  9. Cross-Border Requests
  10. Subprocessor Requests
  11. Transparency Reporting
  12. Policy Exceptions
  13. Roles and Responsibilities
  14. Policy Review
  15. Related Documentation
  16. Version History

1. Purpose​

The purpose of this Government and Public Authority Data Request Policy is to define how Aventora responds to requests for access to customer data from public authorities while protecting customer privacy and complying with applicable laws.

Aventora processes customer data on behalf of enterprise customers through its AI-powered customer engagement platform. Customer data belongs to the customer. Aventora is committed to protecting that data and to honoring only those requests that are legally valid, properly scoped, and subject to appropriate internal review and approval.

This policy:

  • Establishes a consistent process for evaluating and responding to government and public authority data requests;
  • Ensures that disclosures are limited to the minimum information legally required;
  • Preserves customer notification and transparency wherever permitted by law;
  • Supports alignment with common privacy law themes relevant to government access requests without asserting certification status; and
  • Complements related policies, including the Personal Data Privacy & Protection Policy and Data Classification and Handling Policy.

2. Scope​

This policy applies to:

AreaDescription
Aventora personnelAll employees, contractors, and authorized agents who may receive, process, or respond to public authority requests
Customer dataData submitted to, generated by, or stored within Aventora-managed environments in connection with contracted services, including personal information processed on behalf of customers
Production systemsCloud and hosted environments, administrative applications, and supporting infrastructure used to operate Aventora services
SubprocessorsThird-party vendors engaged by Aventora that process customer data on Aventora’s behalf and that may receive public authority requests relating to Aventora customer data

This policy applies across Aventora-managed cloud deployments, customer-managed and self-hosted deployments, and hybrid configurations. Where a customer operates Aventora software in its own environment, the customer remains primarily responsible for responding to requests directed to systems under the customer’s control. Aventora SHOULD assist the customer where contractually agreed and legally permitted.

3. Guiding Principles​

Aventora applies the following principles to every public authority data request:

PrincipleCommitment
Customer data belongs to the customerAventora processes customer data only to deliver contracted services. Aventora does not sell, rent, or license customer data. Disclosures to public authorities are made only where legally required.
Individual evaluationEach request is evaluated on its own merits, including legal validity, scope, jurisdiction, and applicable contractual obligations.
Lawful requests onlyAventora honors only requests that are legally valid under applicable law and supported by appropriate legal process or authority.
Data minimizationAventora discloses only the minimum information legally required to comply with a valid request. Unrelated customer data MUST NOT be disclosed.
TransparencyAventora maintains transparency with affected customers and, where legally permitted, through aggregate reporting. Customer identities MUST NOT be disclosed in public transparency reports.

These principles align with Aventora’s broader privacy commitments described in the Personal Data Privacy & Protection Policy.

4. Types of Requests​

Public authority requests MAY take various forms depending on jurisdiction and the nature of the inquiry. Aventora evaluates each request according to the verification process in Section 5 regardless of how it is labeled.

Request typeDescription
Court ordersJudicial orders requiring production of information, including orders issued by civil or criminal courts
Search warrantsWarrants authorizing search and seizure of specified information, typically issued under criminal procedure laws
SubpoenasCompulsory process requiring testimony or production of documents, including administrative, civil, or criminal subpoenas
Regulatory requestsRequests from government regulators, supervisory authorities, or agencies exercising statutory inspection or enforcement powers
National security requestsRequests issued under national security, intelligence, or similar authorities, including orders that may restrict disclosure to the customer or to the public
Emergency disclosure requestsRequests asserting an imminent risk to life or serious physical harm that require immediate evaluation under Section 12

The label attached to a request does not, by itself, establish its legal validity. Aventora MUST verify the authority, jurisdiction, and authenticity of each request before any disclosure.

5. Verification Process​

No customer data MAY be disclosed in response to a public authority request until the following verification and approval steps are completed:

5.1 Identity and Authority​

Aventora MUST verify:

  • The identity of the requesting individual and their affiliation with the stated agency;
  • That the requesting agency has legal authority to issue the request; and
  • That the request is directed to Aventora in connection with data Aventora holds or controls.

Where permitted, Aventora SHOULD contact the requesting agency through independently verified contact information to confirm the request.

5.2 Jurisdiction​

Aventora MUST evaluate whether the requesting authority has jurisdiction over the data or processing activity at issue. Cross-border considerations are addressed in Section 9.

Aventora MUST validate the authenticity of legal documents supporting the request, including seals, signatures, case references, and other identifying details. Unsigned, informal, or incomplete requests SHOULD NOT be treated as legally binding unless counsel confirms otherwise under applicable law.

All public authority requests MUST undergo legal review before any disclosure. Legal review SHOULD assess:

  • Validity and enforceability of the request;
  • Scope of data sought relative to the legal basis cited;
  • Applicable privacy, data protection, and contractual obligations;
  • Whether the customer should be notified or permitted to respond directly; and
  • Whether applicable law permits narrowing, challenging, or redirecting the request.

5.5 Executive Approval​

Executive approval IS REQUIRED before releasing customer data in response to any public authority request, except where immediate disclosure is legally required to prevent imminent risk to life or serious harm as described in Section 12.

Approval records MUST be retained in the request log described in Section 8.

6. Customer Notification​

Aventora is committed to notifying affected customers promptly unless prohibited by law.

6.1 Standard Notification​

Where legally permitted, Aventora SHOULD:

  • Notify the affected customer promptly upon receipt of a public authority request relating to that customer’s data;
  • Provide the customer an opportunity to respond directly to the requesting authority where appropriate;
  • Redirect the request to the customer where permitted and where the customer holds or controls the responsive data; and
  • Include details of the request, including the requesting authority, legal basis, scope, and response timeline, to the extent legally permitted.

6.2 Delayed Notification​

Where notification is prohibited by law (for example, by gag order, national security order, or similar restriction), Aventora MUST:

  • Document the prohibition and its expected duration in the request log;
  • Limit internal access to information about the request on a need-to-know basis; and
  • Notify the affected customer immediately after the prohibition expires, unless a new lawful restriction applies.

6.3 Contractual Obligations​

Customer notification SHOULD also comply with applicable services agreements and data processing addenda. Where contractual notification timelines are stricter than this policy, the stricter requirement SHOULD prevail unless prohibited by law.

7. Data Disclosure​

When disclosure is legally required and approved under this policy, Aventora MUST apply the following controls:

7.1 Data Minimization​

Aventora MUST disclose only information specifically required by the valid legal process. Personnel MUST NOT disclose data beyond the scope of the request.

7.2 Scope Limitation​

Disclosures MUST be limited to:

  • The customer account, records, or data categories identified in the request;
  • The time period specified in the request, or the narrowest period necessary to comply if no period is specified; and
  • The format reasonably required to comply, preferring structured exports over broad system access where feasible.

Unrelated customer data, data belonging to other customers, and internal Aventora business information MUST NOT be disclosed unless specifically and lawfully required.

7.3 Secure Transmission​

Disclosed information MUST be transmitted using secure methods appropriate to the sensitivity of the data, such as encrypted delivery to verified agency contact points. Credentials, encryption keys, and bulk unfettered system access SHOULD NOT be provided unless specifically and lawfully required.

7.4 Documentation​

All disclosures MUST be documented in the request log described in Section 8, including the data categories disclosed, approvers, and delivery method.

8. Request Log​

Aventora MUST maintain an internal record of all public authority data requests and related disclosures. The request log SHOULD be maintained in a restricted system accessible only to authorized personnel.

Each log entry SHOULD include, at minimum:

FieldDescription
DateDate the request was received and, where applicable, date of disclosure
Requesting authorityName and jurisdiction of the requesting agency
Legal basisType of legal process cited (for example, warrant, subpoena, regulatory order)
Customer affectedIdentifying information sufficient for internal tracking; access limited on a need-to-know basis
Data disclosedCategories and scope of data disclosed, or notation that no data was disclosed
ApprovalsLegal review outcome and executive approver
Notification statusWhether the customer was notified, notification was delayed, or notification was prohibited

Log records MUST be retained in accordance with Aventora’s legal, regulatory, and records-management obligations.

9. Cross-Border Requests​

Public authority requests MAY originate from jurisdictions other than where customer data is stored or where the customer is located. Aventora MUST evaluate cross-border requests carefully before disclosure.

9.1 Jurisdictional Assessment​

Aventora MUST assess whether the requesting authority has a lawful basis to compel disclosure of data within Aventora’s control, considering:

  • The location of the data and processing activity;
  • The nationality or residence of affected individuals, where relevant;
  • Conflicts between the requesting jurisdiction and the jurisdiction of data storage or customer operations; and
  • Applicable contractual commitments to customers.

Where applicable law requires a cross-border transfer mechanism or mutual legal assistance process, Aventora SHOULD require appropriate legal mechanisms before disclosure. Aventora MAY challenge or seek clarification of requests that lack a recognized legal basis for cross-border production.

9.3 Privacy Law Considerations​

Before disclosing data subject to privacy laws, Aventora MUST consider obligations under applicable frameworks, including where relevant:

FrameworkConsiderations for government access requests
GDPR / UK GDPRLawfulness of processing and disclosure; processor obligations to the customer; restrictions on transfers; potential notification duties; and rights of data subjects where applicable
PIPEDA (Canada)Limits on disclosure without knowledge or consent; accountability; and transparency obligations
CCPA / CPRA (California)Customer and consumer notice obligations where applicable; limits on disclosure inconsistent with applicable California law; and contractual commitments
Other applicable lawsProvincial, state, federal, and sector-specific requirements depending on customer location and deployment configuration

This policy SHOULD be interpreted alongside customer agreements and applicable law. Aventora does not claim comprehensive compliance with every global privacy regime based on this document alone. See Compliance.

10. Subprocessor Requests​

Aventora engages subprocessors that may process customer data on Aventora’s behalf. See the Subprocessor Annex.

10.1 Notification to Aventora​

Subprocessor agreements MUST require subprocessors to notify Aventora immediately upon receiving a public authority request relating to Aventora customer data, unless legally prohibited from doing so.

10.2 Aventora-Led Response​

Unless legally required otherwise, Aventora SHOULD coordinate the response to public authority requests affecting customer data processed by subprocessors. Subprocessors MUST NOT disclose Aventora customer data in response to a public authority request without Aventora’s prior written authorization, except where the subprocessor is legally compelled to disclose immediately and cannot reasonably delay.

10.3 Contractual Flow-Down​

Aventora SHOULD flow down requirements consistent with this policy in subprocessor agreements, including data minimization, secure transmission, assistance with customer notification, and cooperation with Aventora’s legal review process.

11. Transparency Reporting​

Aventora is committed to transparency regarding government access requests where legally permitted.

11.1 Aggregate Reporting​

Aventora MAY publish aggregate statistics regarding government and public authority data requests, such as:

  • The number of requests received during a reporting period;
  • The number of requests resulting in disclosure, no disclosure, or partial disclosure;
  • The number of requests subject to disclosure prohibitions; and
  • High-level breakdowns by request type or jurisdiction where permitted.

11.2 Protection of Customer Identities​

Public transparency reports MUST NOT identify individual customers, data subjects, or specific investigative matters unless legally required. Aggregate reporting SHOULD use ranges or rounded figures where necessary to prevent re-identification.

11.3 Internal Reporting​

Aventora Security SHOULD provide periodic internal summaries to executive management regarding the volume, type, and outcome of public authority requests.

12. Policy Exceptions​

12.1 Emergency Disclosure​

Immediate disclosure MAY occur only where Aventora reasonably believes disclosure is legally required to prevent imminent risk to life or serious physical harm, and where there is insufficient time to complete the standard verification and approval process.

In emergency circumstances, Aventora SHOULD:

  • Disclose only the minimum information necessary to address the emergency;
  • Obtain verbal or written confirmation of authority as soon as practicable;
  • Document the basis for emergency disclosure promptly; and
  • Complete retrospective legal review and executive notification as soon as practicable after disclosure.

12.2 Other Exceptions​

Exceptions to this policy MAY be granted only where:

  • A legitimate legal or operational requirement exists;
  • Legal counsel has documented the basis for the exception;
  • The exception is approved in writing by executive management or designated authority;
  • The exception is time-bound and recorded in the request log; and
  • Affected customers are notified where permitted by law and contract.

13. Roles and Responsibilities​

RoleResponsibilities
Privacy OfficerOversees customer notification strategy; advises on privacy law obligations (including GDPR, PIPEDA, and CCPA/CPRA themes); reviews request handling for alignment with customer agreements; supports transparency reporting
Information Security OfficerOwns secure handling and transmission of disclosed data; restricts access to request records and responsive data on a need-to-know basis; ensures production system access during request fulfillment follows least privilege; maintains this policy with Aventora Security
Executive ManagementApproves disclosures of customer data; allocates resources for legal review and compliance; approves transparency reports and material policy exceptions; ensures accountability for lawful request handling
EngineeringLocates and extracts responsive data under direction of legal and security leadership; implements technical controls to prevent over-disclosure; preserves audit records of extraction activities; does not release data without required approvals

Until formally designated, the Privacy Officer and Information Security Officer functions may be fulfilled by Aventora Security or other qualified personnel.

13.1 Reporting Channels​

Public authority requests received by any Aventora personnel MUST be forwarded immediately to Aventora Security at security@aventora.ai. Personnel MUST NOT respond directly to a request without following this policy.

14. Policy Review​

Aventora Security MUST review this policy:

  • At least annually; and
  • Immediately following material legal or regulatory changes affecting government access to data, cross-border disclosure, or customer notification obligations.

Review outcomes SHOULD be documented, including approved revisions, open remediation items, and the next review date. Material changes require re-approval per the Approval section above.

For questions regarding this policy or public authority requests:

16. Version History​

VersionDateAuthor / OwnerSummary of Changes
1.0July 6, 2026Aventora SecurityInitial publication of Government and Public Authority Data Request Policy.