Complaints Procedure

CI-IT B.V.

Introduction

This procedure applies to all investigative assignments conducted by CI-IT B.V. as a private investigation firm. The full text is available at www.ci-it.nl so that clients and data subjects can understand how and with whom they can file a complaint.

Whereas: It is important that clients and data subjects are able to have their dissatisfaction with the execution of an investigative assignment reviewed by an independent complaints committee when consultation with the investigator concerned or the management does not lead to a resolution.

Article 1 — Definitions

  • Client: the natural person or legal entity that commissions an investigation from CI-IT B.V.
  • Data Subject: the individual who is the subject of an investigation commissioned by the Client.
  • Complaint: any written expression of dissatisfaction regarding the execution or negligence of an investigative assignment, addressed to the complaints committee.
  • Complainant: the client, data subject, or their authorized representative who submits a complaint.
  • Complaints Committee: a committee comprising the director of CI-IT B.V. and at least one independent officer with no interests in CI-IT B.V. or the assignment concerned.
  • Respondent: CI-IT B.V. or the employee to whom the complaint relates.

Article 2 — Admissibility

  1. The complainant may submit a written complaint to the complaints committee within six weeks of the event in question. This aligns with the standard period stipulated in the circular accompanying the Regulations for Private Security Organizations and Investigation Firms.
  2. A complaint submitted later may still be considered if the committee determines that the complainant could not reasonably have been expected to submit the complaint earlier.
  3. Complaints are treated confidentially. Files are accessible only to the committee and those directly involved and are securely destroyed after three years.

Article 3 — Composition and Duties of the Complaints Committee

  1. The committee consists of the director of CI-IT B.V. and at least one independent officer.
  2. The committee investigates submitted complaints, hears the parties involved, and formulates a judgment on the merits of the complaint.

Article 4 — Complaints Procedure

  1. Within five business days of receipt, the committee will confirm in writing that the complaint has been received.
  2. The committee assesses admissibility. In the event of non-admissibility, the complainant will be notified of the reasons.
  3. If the complaint is admissible, a written response will be requested from the investigator concerned; a copy of this response will be sent to the complainant.
  4. If necessary, the committee will hear the complainant and respondent in each other's presence, with the possibility of postponement under reasonable conditions.
  5. If no resolution is reached, the complainant may appeal to an independent third party appointed by CI-IT B.V. who has no ties to the firm. This third party will issue a binding decision within a reasonable period.

Article 5 — Judgment of the Complaints Committee

  1. Within four weeks of receiving a complaint, the committee will issue a written recommendation. This period may be extended twice by a maximum of four weeks; the complainant will be notified accordingly.
  2. The recommendation includes the reasoning and any recommendations. Both the complainant and respondent will receive a copy.
  3. The decision of the independent third party on appeal is binding, and any consequences will be implemented by CI-IT B.V. as soon as possible.

Article 6 — Final Provisions

  1. A copy of every complaint and its outcome will, in accordance with the circular, be brought to the attention of the Minister of Justice and Security.
  2. This complaints procedure has been established by the management of CI-IT B.V. and takes effect on the date of publication on www.ci-it.nl.