Compliance & Ethics

Introduction

Compliance, Ethics, and Data Integrity Policy

Friar Genealogical Research, LLC operates in accordance with applicable laws and professional standards relevant to genealogical and investigative research within the United States. We aim to maintain responsible practices consistent with industry expectations for accuracy, discretion, and ethical conduct. Our work spans two distinct sectors: providing clarity to private individuals discovering their family histories, and delivering accurate investigative leads to assist the justice system. Because these fields operate under fundamentally different legal frameworks and consumer agreements, we strictly segregate our methodologies. This policy outlines our operational boundaries, ensuring full compliance with both consumer platform Terms of Service and federal law enforcement mandates.

Section A: Private & Consumer Genealogy Compliance

1. Scope of Private Services

This section governs all genealogical research conducted for private clients. This includes cases of unknown parentage, adoptions, family tree reconstruction, and historical research. These services are entirely separate from our law enforcement and forensic operations. They are bound by distinct legal, ethical, and platform-specific restrictions.

2. Adherence to Platform Terms of Service (ToS)

Our analysts strictly respect the digital boundaries and user agreements of all consumer genomics platforms.

• Authorized Databases Only: Research utilizing consumer DNA databases (including AncestryDNA, 23andMe, and MyHeritage) is conducted exclusively within accounts created and authorized by the DNA kit owner or their legally designated representative.
• Prohibition of Third-Party Forensic Uploads: We strictly prohibit the upload of any data, profiles, or files originating from law enforcement investigations, criminal casework, or unauthorized third-party sources to consumer databases that bar such activity in their Terms of Service.
• Platform Compliance Updates: We actively monitor changes to consumer database user agreements to ensure our methodology remains fully compliant with platform policies at all times.

3. Informed Consent and Right to Privacy

We believe that genetic data belongs solely to the individual. We enforce rigid consent standards before initiating any private genetic genealogy research.

• Written Authorization: No third-party DNA data will be analyzed or uploaded on behalf of a private client without explicit, signed, written informed consent from the testing individual.
• Surrogate Consent: In cases involving deceased individuals, minor children, or legally incapacitated adults, research will only proceed upon validation of documented legal authority (e.g., executorship, legal guardianship, or power of attorney).
• Right of Revocation: Clients retain the absolute right to revoke consent and terminate research at any point. Upon revocation, all active research on their genetic profile will cease immediately.

4. Private Client Confidentiality and Data Safeguards

All private research findings, genetic data, and identified biological connections are treated as highly confidential proprietary information.

• Information Siloing: Private client family trees and DNA match data are strictly segregated from our law enforcement case tracking systems to prevent cross-contamination of data.
• Third-Party Disclosure: We will never disclose, sell, or share a private client’s genetic info, family trees, or identity to any external party, including law enforcement agencies, unless compelled to do so by a valid, legally binding court order or subpoena.
• Integration with WISP: Digital files, raw DNA data downloaded for analysis, and client communications are securely stored and handled in strict alignment with our Written Information Security Program (WISP).

Section B: Law Enforcement & Forensic Genetics (FIGG) Compliance

1. Scope and Statutory Alignment

This section governs all forensic casework, investigative genetic genealogy (IGG), and consulting services provided to law enforcement agencies, prosecutors, and government entities. All forensic operations are conducted in strict compliance with the U.S. Department of Justice (DOJ) Interim Policy on Forensic Genetic Genealogical DNA Analysis and Searching, as well as any applicable state or local statutory mandates regarding forensic genealogy.

• Strictly Analytical Scope: Friar Genealogical Research, LLC operates strictly as an analytical, digital, and genealogical consulting entity. We perform computer-based data analysis and tree construction only. We do not operate a biological laboratory, nor do we accept, possess, store, or process physical biological evidence, tissue samples, or reference swabs under any circumstances. All wet-lab processing, sequencing, and physical sample management must be handled entirely by the authorizing agency or their accredited laboratory partner prior to our analysis.

2. Case Eligibility and Investigative Exhaustion

We enforce strict threshold requirements before accepting any law enforcement or forensic case to ensure the ethical and legal use of genetic data.

• Authorized Offense Restrictions: Investigative services are strictly limited to the identification of unidentified human remains (UHR), or cases involving violent crimes as defined by federal and state standards (e.g., homicide, non-negligent manslaughter, and forcible sexual assault).
• Exhaustion of Traditional Methods: Prior to initiating forensic genetic genealogy, the investigating agency must certify that traditional investigative avenues—including a search of the Combined DNA Index System (CODIS)—have been fully exhausted and have failed to yield a workable lead.

3. Authorized Forensic Databases and ToS Compliance

We maintain a zero-tolerance policy for unauthorized database utilization. Analysts will only search profiles within platforms that legally and explicitly permit law enforcement investigative access.

• Approved Platforms Only: Forensic profiles will only be uploaded to public consumer databases or specialized repositories whose Terms of Service (ToS) explicitly allow law enforcement searching and FGG investigative tracking (e.g., GEDmatch PRO, FamilyTreeDNA).
• Strict Avoidance of Private Repositories: Under no circumstances will our analysts upload law enforcement samples, forensic profiles, or data derived from forensic casework to consumer platforms that explicitly bar law enforcement utilization (e.g., AncestryDNA, 23andMe).

4. Evidence Integrity and Data Minimization Protocols

We protect the integrity of the investigative process and the privacy of genetic networks by enforcing strict digital data-destruction workflows upon case resolution.

• Database Destruction Requests: Immediately upon the conclusion of the investigation, the identification of an individual, or the formal termination of the contract, we will formally instruct and request the authorized forensic databases to permanently delete and purge the uploaded forensic DNA data file from their systems.
• Destruction of Internal Analytical Files: In alignment with our Document Retention & Destruction Policy, all electronic files—including raw data files (e.g., BAM, FASTQ, or TXT), case-specific research trees, and match lists held on our internal systems—will be permanently deleted immediately upon project completion or contract termination.
• No Physical Sample Handling: Friar Genealogical Research, LLC operates strictly as an analytical and investigative consulting entity. We do not operate a biological laboratory, nor do we accept, store, or process physical biological evidence, tissue samples, or reference swabs under any circumstances.

5. Jurisdictional and State-Specific Variations

While our internal processes align strictly with federal guidelines, we recognize that several states enforce statutory regulations that impose additional legal requirements on Forensic Genetic Genealogy.

• Agency Compliance Mandate: The requesting law enforcement agency is solely responsible for ensuring that all state-specific statutory prerequisites—including obtaining judicial warrants (as required in states like Montana), secure court orders (as required in Maryland), or prosecutor concurrences—have been fully executed prior to transferring any digital data files to our firm.
• Refusal of Non-Compliant Casework: Friar Genealogical Research, LLC reserves the right to audit intake documentation and refuse any casework originating from a jurisdiction where the mandated legal benchmarks have not been verified.

Professional Boundaries

We maintain clear professional boundaries in all research engagements.

This includes:

• Working only within the agreed scope of services
• Avoiding conflicts of interest where possible
• Declining work that requires unethical or improper use of information
• Maintaining independence in research conclusions

We do not provide legal determinations, legal representation, or identity certification.

Data Handling Philosophy & Respect for Individuals

While our standalone Privacy Policy strictly governs how data is collected, stored, and retained, our broader ethical approach to information handling emphasizes dignity, privacy, and respect for both living and deceased individuals. We commit to:

• Minimizing the unnecessary handling, exposure, or disclosure of sensitive personal details.
• Treating all historical records, genetic data, and research materials with equal discretion and care.
• Exercising extreme discretion when handling or tracking information regarding living individuals.
• Respecting the context, dignity, and sensitivity of all historical and familial records.
• Archiving or closing files responsibly immediately upon the completion of contractual work.
• Strictly utilizing retrieved information for legitimate, authorized research purposes within the defined scope of engagement.

Under no circumstances does Friar Genealogical Research, LLC engage in harassment, targeting, unauthorized surveillance, or the misuse of personal data.

3. Use of Public Records & Research Integrity

We utilize publicly available records, archival materials, and client-provided documentation as part of our core research process. Recognizing that genealogical research is inherently interpretive, our professional standards require that:

• Source materials are evaluated responsibly and applied strictly within their proper historical context.
• Final findings are based on verifiable, documented records rather than speculation, assumption, or guesswork.
• Our reports clearly distinguish between verified, confirmed findings and reasonable genealogical inference or hypotheses.
• Analysts proactively highlight and acknowledge any gaps, inconsistencies, or ambiguities in historical documentation.

We maintain a zero-tolerance policy for data fabrication. We do not alter, manipulate, or misrepresent historical source materials or genetic data under any circumstances.

Federal Contractor Registration & Analytical Scope

Registered with SAM.gov as a federal contractor, confirming compliance with government standards for vendor verification, data handling, and ethical conduct. Our operations are strictly limited to digital database evaluation and genealogical tree analysis; we do not manage third-party laboratory vendors, sample tracking, or extraction pipelines.

Disclaimer

Friar Genealogical Research, LLC is an independent research entity and is not affiliated with, endorsed by, or acting on behalf of any law enforcement agency or government body. Any references to investigative standards, methodologies, or professional guidelines (including those associated with law enforcement or genetic genealogy best practices) are used solely to describe internal research approaches and do not imply formal certification, authorization, or endorsement. All research outputs are provided for informational and genealogical purposes only and do not constitute legal advice, legal determinations, or guarantees of investigative outcomes.

Research Limitations

We acknowledge inherent limitations in genealogical and investigative research, including:

• Incomplete or missing historical records
• Variations in record accuracy over time
• Ambiguity in historical documentation
• Limitations in access to certain records or archives

All findings and research outputs should be understood and evaluated within these realistic constraints.

Policy Updates

This Ethics & Compliance statement may be updated periodically to reflect changes in professional standards or operational practices. Updates will be posted with a revised “Last updated” date below. [1, 2, 3]

Last Updated: June 2026