Unregistered Trainee, Backdated Supervision, and a Client Report

Several separate problems exist, and they compound one another. First, Nadia is performing compensated private-detective services before the Act’s employee-registration requirement is satisfied. The agency’s license and the owner’s personal license do not authorize an unregistered person to conduct surveillance or generate client work product. Second, using an old case number mislabels the matter and corrupts the agency’s records. Third, backdating a supervision log is deliberate falsification; a later dated memo can correct a record, but it cannot make it appear that supervision occurred earlier. Fourth, sending raw client evidence from a personal phone creates confidentiality, authentication, and retention failures.

Immediate steps: stop Nadia’s case work; collect and preserve the phone and video through the agency’s evidence process with a hash and chain-of-custody log; assign a registered/licensed investigator to independently review the footage; do not issue a report claiming the owner personally supervised work the owner did not supervise; write a dated corrective memo describing what happened; notify counsel and consider a self-report to IDFPR; and tell the client that the report is delayed pending compliance review without disclosing unnecessary details. Do not destroy the old case-number draft or the owner’s instruction-preserve them for the compliance file.

The safest compliance position is no, at least not as a normal invoice for private-detective services. The Act is designed to prevent unlicensed or unregistered persons from being compensated for detective work; billing the client as if a compliant investigator performed the work would misrepresent the service and could be treated as benefiting from unlicensed activity. The fact that the video is useful does not cure the licensing defect.

The agency should consult counsel before issuing any invoice, disclose the issue to the client, and be prepared to credit or refund the three days. If a licensed/registered reviewer later performs a genuine, documented review, the agency might bill only for that lawful work, but it should not simply relabel Nadia’s hours. It should also preserve time records and not alter them. Beyond licensure, a false invoice could create contract, insurance, and professional-discipline exposure.

The report should be factual and transparent: matter identification with the correct current case number, client and scope, dates and times of surveillance, personnel and their credential status, methods, locations, a complete evidence inventory, chain-of-custody references, and limitations. The signature must be by the licensed/registered investigator who actually reviewed the evidence and can attest to the report; a reviewer may sign as reviewer, but the owner must not sign as if personally supervising. The report should include both incriminating and exculpatory observations-selective omissions create a misleading report.

For the raw video, the agency may provide a copy to the authorized client, but it should retain the original or working copy, use secure transfer, log the release, and explain that the client may not further distribute it without consent. Do not send the personal-phone original as the agency record; do not backdate; do not create a false supervision log. If the client demands the owner’s signature on a report the owner did not supervise, refuse and explain the credentialing issue in writing.