June 2008
We were asked to clarify whether Document Examiners must be licensed as private investigators, pursuant to Section 1702.104.
The review, analysis, or comparison of documents, per se, is not “investigative” for purposes of the Private Security Act. The examination of documents constitutes the provision of investigative services only when information is to be obtained on a specific (known) person.
For instance, a general or theoretical conclusion, such as “whoever wrote this is going to commit suicide”, would not constitute “information regarding a specific person”. Whereas, if the examiner is told “these are the documents supposedly signed by Mr. S -- find out who really signed them, or tell me what you can about Mr. S’s emotional state, etc.,” such matters would constitute an investigation.