Conflicting Personal Relationship

A subject is influenced by a personal, familial, romantic, or close social relationship with an individual whose interests are affected by the subject’s organizational responsibilities.

The relationship may involve a colleague, applicant, customer, supplier representative, contractor, investigation subject, complainant, or another person connected to an organizational decision. The conflict may arise where the subject can approve access, influence recruitment, award work, alter a case outcome, disclose information, suppress scrutiny, or provide another form of preferential treatment.

The existence of a personal relationship does not itself establish harmful intent. The investigative concern arises where the relationship creates a material conflict with the subject’s duties and is not disclosed through the organization’s required process. Relevant indicators may include repeated favorable decisions, unusual access to information concerning the connected person, involvement in matters from which the subject should have recused themselves, or communications inconsistent with the stated professional relationship.

Investigators should establish the nature and timing of the relationship, the subject’s disclosure obligations, the decisions or access affected by it, and whether the subject took steps to conceal the connection. The resulting infringement may separately involve abuse of decision-making authority, unauthorized data access, data disclosure, fraud, or interference with an investigation.