- Remember the past? How we used to keep all our information on paper; and when a regulator came knocking on the door it was so simple to help them find what they needed.
- And now? Now we have data, endless data, and there is no end to the complexity of its structure, no end to its life, its value.
- But some data may fade almost from sight, out of mind and memory, hidden. Unprotected.
- So what would happen if someone with antitrust on their mind and authority on their side came knocking on your door one morning wanting to seize your data, every last little byte—with no word of warning?
- Could you direct them to what they need? Would you know which is privileged, which is out of scope and yours to keep safe?
- One day you’ll sort it out. You’ll know how to get hold of your gigabytes, weed out your kilobytes.
- But what if there is a dawn raid?
- Best be ready, risk ready.
- Don’t leave it all up to the wonderful people in IT. IT are just part of the solution: you need all your people to work together in synch.
- Find out from us what to do and who has to do it, so you can tell everyone, step by step, byte by byte. It’s all in the detail and we know the detail.
- Get it right and you get to sleep at night and enjoy the dawn when it arrives.
Why you should update your dawn raids protocols
Unannounced inspections or ‘dawn raids’ are used by antitrust authorities to obtain evidence when there are suspicions that individuals or businesses have infringed the antitrust rules. Often triggered by tip-offs from whistleblowers or confessions from leniency applicants, dawn raids provide investigators with an opportunity to swoop and seize information for subsequent interrogation and review. The surprise element of dawn raids offers reassurances to investigators that evidence of a possible infringement will not be destroyed.
Many businesses will have protocols for responding to a dawn raid. Typically, these include notes for receptionists on what do to if investigators arrive and detailed guidance for compliance teams about the need to ‘shadow’ investigators as they move around the office and to photocopy all documents before they are taken away. The issue that these protocols ought to cover – but often don’t – is how to deal with the arrival of digital forensic investigators.