CTSO Central is a platform operated by Clearpoint Business Group, LLC ("we," "us," or "our") for managing members, chapters, conferences, competitions, and testing for Career and Technical Student Organizations (CTSOs) such as DECA, FBLA, and HOSA. We are committed to protecting the privacy of our users while complying with applicable laws. These guidelines are intended to assist law enforcement officials who seek information from Clearpoint Business Group regarding CTSO Central user accounts. They do not create any enforceable rights or obligations, and Clearpoint Business Group reserves the right to update them at any time.

Nothing in these guidelines limits Clearpoint Business Group's ability to raise legal or factual defenses to any law enforcement request.

Applicability

These guidelines apply to all law enforcement requests directed at Clearpoint Business Group for data associated with CTSO Central accounts. They cover requests from federal, state, and local agencies within the United States, as well as international requests submitted through proper channels. Requests related to other Clearpoint Business Group products or services should be directed to legal@clearpointbusiness.com for routing.

Types of Legal Process

The type of legal process required depends on the category of information sought.

Subpoenas

A valid federal or state grand jury subpoena, civil subpoena, or administrative subpoena may be used to compel disclosure of basic subscriber information, including:

Name, email address, phone number, and mailing address
Account creation date and account type (student, advisor, chapter administrator)
Billing contact name, payment method type, and billing address (where applicable)

Court Orders

A court order issued under 18 U.S.C. Section 2703(d) or an equivalent state statute may be used to compel disclosure of the records described above, plus:

Historical login records, including IP addresses, dates, and times
Session metadata, such as browser type and device identifiers
Account activity logs, including actions performed on the platform (e.g., conference registrations, competition submissions)

Search Warrants

A search warrant issued by a federal or state court upon a showing of probable cause is required for disclosure of stored content and other non-public data, including:

Competition entries, project files, and uploaded documents
Test and assessment responses and scores
Private messages, notes, or other communications stored on the platform
Member and advisor roster data, chapter affiliations, and organizational role assignments
Conference registration and attendance records

Clearpoint Business Group requires a search warrant for all content disclosures. We interpret the Stored Communications Act (18 U.S.C. Sections 2701-2712) to require a warrant for stored content, regardless of age.

Customer Information Collected and Retained

CTSO Central may collect and retain the following categories of information during normal platform operations:

Account and Identity Data

Full name, email address, phone number, and mailing address
Username, hashed account credentials, and account role (student member, advisor, chapter administrator, state/national officer)
School name, chapter name, and CTSO affiliation
Date of birth (where provided for age verification or eligibility purposes)
Parent or guardian contact information (where provided for minor users)

Academic and Competition Data

Competition event registrations, entries, scores, and results
Test and assessment records, including item-level responses (where retained)
Conference and event registration, attendance, and participation records
Chapter-level roster and membership data

Technical and Transactional Data

IP addresses, browser user agent strings, and device identifiers
Login timestamps, session duration, and access logs
API request logs (retained for a limited period)
Payment transaction records, including amounts and dates (full payment card numbers are not stored by Clearpoint Business Group)

Retention Periods

Data retention periods vary by category. Account and identity data is generally retained for the life of the account plus a reasonable period following deletion. Technical logs such as IP addresses and access records are typically retained for up to 12 months. Competition and testing records may be retained for longer periods to support organizational record-keeping requirements. Clearpoint Business Group does not guarantee that specific data will be available for any particular time period.

Protections for Minor Users

A significant portion of CTSO Central users are minors (individuals under the age of 18). Clearpoint Business Group takes additional care when responding to requests involving minor users' data.

All requests involving accounts identified as belonging to minor users will receive heightened scrutiny.
Clearpoint Business Group may require additional documentation or narrowing of requests that are overly broad in scope when minor users' data is involved.
We encourage law enforcement to minimize the collection of data related to minors who are not the subject of an investigation.
Clearpoint Business Group complies with the Children's Online Privacy Protection Act (COPPA) and applicable state laws governing children's data.

User Notification

Unless legally prohibited, Clearpoint Business Group will notify the affected user(s) of a law enforcement request for their data at least 7 to 10 days before disclosure. Notification allows users the opportunity to seek legal counsel or challenge the request.

In emergency situations involving imminent threats, notice periods may be shortened at Clearpoint Business Group's discretion.

Law enforcement officials seeking to prevent user notification must obtain a court order under 18 U.S.C. Section 2705(b) or an equivalent state provision. The order must specifically direct Clearpoint Business Group to delay notification and state the applicable duration. Clearpoint Business Group will comply with valid non-disclosure orders for the period specified and will notify the user when the order expires, unless renewed.

Informal requests to withhold notification, without a court order, will not be honored.

Data Preservation Requests

Clearpoint Business Group will preserve account records for 90 days upon receipt of a valid preservation request, in accordance with 18 U.S.C. Section 2703(f). A single 90-day extension may be granted upon a renewed request.

Preservation requests must include:

Official agency letterhead
Signature of the authorized requesting officer
The specific CTSO Central account(s) to be preserved, identified by username, email address, or other unique account identifier
A valid law enforcement email address for correspondence
A statement that legal process is being pursued for the preserved records
The date and nature of the underlying investigation (to the extent it can be disclosed)

Preservation freezes a copy of the existing account records as of the date of the request. It does not prevent the user from continuing to use their account or deleting data. Preserved data will only be disclosed pursuant to valid legal process.

International Law Enforcement Requests

Clearpoint Business Group is a United States company. We require that international law enforcement requests for user data be submitted through formal U.S. legal channels, including:

A Mutual Legal Assistance Treaty (MLAT) request submitted through the U.S. Department of Justice
A letter rogatory issued by a foreign court and domesticated by a U.S. court

Clearpoint Business Group may respond to international requests made under an applicable executive agreement pursuant to the Clarifying Lawful Overseas Use of Data (CLOUD) Act, where one is in effect.

Emergency requests from foreign law enforcement will be evaluated on a case-by-case basis, subject to the standards described in the Emergency Requests section below.

Emergency Requests

Clearpoint Business Group may voluntarily disclose user information to law enforcement without legal process when we believe in good faith that an emergency involving imminent danger of death or serious physical injury to any person requires immediate disclosure. 18 U.S.C. Section 2702(b)(8) and (c)(4) authorize such disclosures.

Emergency requests must be submitted in writing (email is acceptable for initial contact) and must include:

A detailed description of the emergency, including the nature of the threat
Identification of the person(s) at risk
The specific CTSO Central account(s) or data sought
An explanation of how the requested data will help resolve the emergency
The name, badge or ID number, agency, phone number, and email address of the requesting officer

Clearpoint Business Group evaluates each emergency request individually. Submission of an emergency request does not guarantee disclosure. Clearpoint Business Group reserves the right to request additional information or to decline a request if the circumstances do not meet the standard for emergency disclosure.

Cost Reimbursement

Clearpoint Business Group reserves the right to seek reimbursement for costs incurred in responding to law enforcement requests, as permitted by 18 U.S.C. Section 2706. We may waive fees in emergency situations or where the request is narrowly tailored and involves minimal effort.

Testimony and Expert Witness Requests

Requests for testimony or expert witness appearances by Clearpoint Business Group employees must be made through formal legal process (e.g., a subpoena). All subpoenas for testimony must be personally served on Clearpoint Business Group's registered agent:

Registered Agent

Northwest Registered Agent, LLC
c/o Clearpoint Business Group, LLC
502 W 7th St, Ste 100
Erie, PA 16502, USA

Clearpoint Business Group may require reasonable advance notice (typically 14 business days) and may seek compensation for employee time and expenses associated with testimony, as permitted by law.

Submitting a Request for Information

All law enforcement requests should include the following:

The specific CTSO Central account(s) at issue, identified by username, email address, or other unique identifier
The specific categories of data requested
The legal authority for the request (subpoena, court order, or warrant)
The name, badge or ID number, agency, direct phone number, mailing address, and official email address of the requesting officer
The case or file number associated with the request
The requested response deadline (Clearpoint Business Group will make reasonable efforts to accommodate urgent timelines)

Requests submitted without sufficient identifying information may be returned for clarification.

Contact Information

Email: legal@clearpointbusiness.com
Mail:
Clearpoint Business Group, LLC
Attn.: Legal Department
169 Madison Ave., Suite 15445
New York, NY 10016

Clearpoint Business Group accepts law enforcement requests by email and postal mail. We do not accept requests by phone or fax.

Guidelines for Law Enforcement