The Unregistered New Hire and the Satellite Office
Dana owns Riverbend Investigations LLC, a Georgia private detective company licensed by the Board. In March she hired Marcus, a retired GBI agent, as an investigator. Marcus submitted his employee registration packet on March 10, but the Board has not issued a registration number. On April 2 Dana assigned Marcus to interview three witnesses in a workers' compensation case and to sign a report under the company's name. Marcus also carries a company business card that identifies him as 'Private Investigator' and has no registration card. Dana opened a second office in another county, listing it on the website as a 'branch' and displaying the same company license number. A competitor complained to the Board. Dana says Marcus is 'supervised' by her and that the branch is only a mailing address. The Board requests records and a written response. Identify the licensing issues and advise Dana before she responds.
1. Does Dana's supervision allow Marcus to interview witnesses and sign reports before his registration is issued? Explain the licensing structure.
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No. Georgia separates the company license from the individual registration of employees who perform investigative work. A licensed company may not use an unregistered person to conduct investigations merely because the owner supervises him. Supervision is not a substitute for registration, and the Board can treat work performed before registration as unlicensed activity. Marcus should not interview witnesses, sign reports, or use a business card calling himself a 'Private Investigator' until the Board issues his registration. The company should document that he is not assigned investigative duties in the meantime, and Dana should correct any implication that he is already authorized. The fact that Marcus is experienced or retired from law enforcement does not change the registration requirement.
2. May Dana advertise and operate the second office as a branch under the existing company license?
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Probably not without Board approval. A company license is tied to the licensed entity and the locations or operations the Board has approved. Opening an additional office can require a separate branch license, a location notification, or an amended application, depending on Board rules. Advertising the location as a 'branch' and displaying the same license number before approval can mislead the public into thinking the site is licensed. Calling it 'only a mailing address' does not resolve the issue if staff meet clients or conduct business there. Dana should remove the branch claim from the website, determine what filing the Board requires for the second location, and keep the office inactive for investigative business until the Board confirms coverage.
3. What should Dana do in response to the Board's records request and complaint?
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Dana should cooperate promptly and truthfully. She should preserve the registration packet, assignment records, reports, business cards, website screenshots, and office lease or mail records. She should not backdate Marcus's registration, create a retroactive supervision log, or describe the branch as approved if it was not. In her written response she should identify what happened, what corrective steps she has taken, and what policies she will adopt to prevent unregistered work. Cooperation and remediation can matter to the Board, but they do not erase the original violation. She should also notify her attorney and insurer if the complaint may lead to formal disciplinary action.