---
title: "Altss Private Markets OSINT Verification Standard | Altss Frameworks"
description: "The Altss standard for verifying publicly accessible private-markets information: Berkeley Protocol-aligned source, item and content verification, the…"
canonical: "https://altss.com/knowledge-center/frameworks/osint-framework-for-private-markets-intelligence"
---

Standard · Version 1.2.0 · Last reviewed 2026-10-02

Source check: Legal statements checked against the cited primary sources on 2026-10-02 ([how](https://altss.com/methodology)). General information, not advice.

# Altss Private Markets OSINT Verification Standard

The Altss standard for verifying publicly accessible private-markets information: Berkeley Protocol-aligned source, item and content verification, the three evidence dimensions with origin kept separate from collection method, source grading, ICD 203 language for judgments, and source-rights recording.

Publisher: Altss LLC Content modified 2026-10-02

LIB-30

Image: Technical drawing of an engine-order telegraph whose dial carries the seven ICD 203 likelihood terms and their ranges, from almost no chance (1-5%) to almost certain (95-99%), with an example judgment on likely.

Reference plate: likelihood stated in one fixed vocabulary.

## 1. Purpose

This standard sets the rules for verifying publicly accessible information about private-markets organisations, funds, people and transactions, and for stating what that information supports.

It is an Altss standard. It adopts the verification approach and the documentation principles of the Berkeley Protocol on Digital Open Source Investigations, the analytic standards of US Intelligence Community Directive 203 for stating judgments, and the two-axis grading of sources and information known as the Admiralty or NATO system. It applies them to commercial research, and records the result in the Altss evidence model, which keeps three questions apart: what kind of source stated a fact (origin), how a value was produced (derivation) and what checking it has passed (validation).

The standard is normative. It says what must be true before a claim may carry a given label. It makes no statement about how Altss collects information, how many sources it uses, how quickly it observes events, or how accurate its records are.

It replaces an earlier page at this address that combined a fundraising targeting workflow with product claims. The targeting workflow is now covered by the [LP Targeting & Prioritization Guide](https://altss.com/knowledge-center/frameworks/lp-targeting-and-prioritization-framework). The product claims have been removed.

## 2. Scope

**In scope**

- The record kept for each evidence item about a private-markets entity or event: identifier, retrieval date, fixed copy or fingerprint, collection method and rights basis.
- Verification of the source, of the item and of its content.
- Assignment of evidence origin, derivation status and validation status.
- Grading of source reliability and information credibility.
- The language used for analytic judgments.
- Recording whether each artefact may be used as evidence (its rights basis), and the general position on personal data.

**Out of scope**

- What a provenance record must contain: [Evidence & Provenance Standard](https://altss.com/knowledge-center/frameworks/evidence-and-provenance-standard).
- Authority classes, reliability grades, confidence labels and the preference order between conflicting sources in detail: [Source Reliability & Confidence Methodology](https://altss.com/knowledge-center/frameworks/source-reliability-and-confidence-methodology).
- Whether two records are the same entity: [Entity Resolution Methodology](https://altss.com/knowledge-center/frameworks/entity-resolution-methodology).
- Review horizons and freshness: [Temporal Data & Freshness Methodology](https://altss.com/knowledge-center/frameworks/temporal-data-and-freshness-methodology).
- Signal classes and what they indicate, which are Altss-defined: Investment Signal Classification Methodology.
- The use of AI tools in research: AI-Assisted Due Diligence & Research Standard.
- How information is searched for, monitored or collected. This standard sets no collection rules (rule 6.6).
- Licensed and other non-public information, except that its origin value is defined here.
- Legal advice on the law of any jurisdiction.

## 3. Definitions

- **Open-source information.** Information that any member of the public can observe, purchase or request without special legal status or unauthorised access. This is the Berkeley Protocol's definition. Under it, information obtained by communicating with individual users, or held behind access restrictions, is closed source.
- **OSINT.** Open-source intelligence. In the US Intelligence Community's definition, intelligence derived exclusively from publicly or commercially available information that addresses specific intelligence priorities, requirements or gaps. In general usage OSINT covers every publicly accessible source, including regulatory filings and official publications. In this standard, OSINT_SOURCED is narrower: it is one of five evidence origin values (rule 6.1). See [open-source intelligence](https://altss.com/glossary/osint).
- **Research requirement.** The written statement of what a research task must establish: the subjects, the attributes and the purpose.
- **Collection.** In the Protocol's terms, gaining possession of online information through a screenshot, a conversion to PDF, a download or another form of capture.
- **Collection method.** How an artefact was obtained. It is recorded separately as process metadata and is never an origin value.
- **Evidentiary copy and working copy.** The unaltered captured item, and the separate copies used for analysis.
- **Verification.** Establishing the accuracy or validity of collected information. The Berkeley Protocol divides it into three considerations, looked at together: the source, the digital item, and its content.
- **First copy found.** The earliest appearance of an item that a researcher has located. The Protocol prefers this term to "the first copy online", because the original may have been removed or shared privately first.
- **Circular reporting.** Repeated reports that trace back to one origin and so look like independent confirmation when they are not.
- **Evidence origin, derivation status, validation status.** The three dimensions of the Altss evidence model, defined in rules 6.1, 6.3 and 6.4. See [data provenance](https://altss.com/glossary/data-provenance) and observed, derived and estimated data.
- **Authority class, reliability grade and credibility grade.** The standing of a source for a type of claim (RECORD_KEEPER, SUBJECT, DIRECT_ACCESS, COPY_OR_COMPILATION or UNATTRIBUTED), a grade of how dependable it has been for that type of claim (A to F), and a grade of how well an item of information is supported (1 to 6), all defined in the Source Reliability & Confidence Methodology. See [source reliability](https://altss.com/glossary/source-reliability).
- **Information, assumption, judgment.** As in ICD 203: information is what sources state; an assumption is a supposition used to frame or support an argument; a judgment is a conclusion based on information, analysis and assumptions.

## 4. Inputs and source types

**4.1 Source families.** The origin value is assigned to each evidence item relative to the subject of the claim (rule 6.1).

| Source family | Examples | Evidence origin | Establishes | Does not establish |
| --- | --- | --- | --- | --- |
| Filings to, and records kept by, a regulator, statutory registry or court, retrieved from that body's own system | [Form ADV](https://altss.com/glossary/form-adv) through the SEC's adviser disclosure site; [Form D](https://altss.com/glossary/form-d) and Form 13F on EDGAR; company registers; LEI records; court dockets | REGULATORY_PUBLIC_RECORD | What the filer stated to the body, as the form defines it, at its date; the body's own register entries | That the filer's statements are true. The SEC states that accepting a Form ADV is not a finding that it was completed correctly. |
| Official publications of public bodies | Public pension board minutes and meeting papers; state treasury and audit-office reports; a sovereign fund's statutory annual report | OFFICIAL_INSTITUTIONAL | The body's own decisions and statements | Facts about counterparties beyond what the body records |
| The subject's own publications and statements | Its website, annual report, press release, investor letter; a statement it gives on request | DISCLOSED | The subject's own acts and its description of itself | Independent confirmation; comparative claims about itself |
| Third-party publications | News reporting; a counterparty's announcement; event programmes; professional directories; archived copies of third-party pages | OSINT_SOURCED | What the third party reports, with attribution | Anything beyond the third party's own access; the content of a filing it describes, until the filing itself is retrieved |
| Licensed or privately supplied material | A licensed dataset; a non-public document supplied with permission | LICENSED_THIRD_PARTY | What the supplier states, used within the licence's terms | It is not open-source information, and it is cited publicly only where the licence allows |

**4.2 What common US filings do and do not show.**

- **Form ADV** describes an investment adviser: its registration or exempt reporting status, the types and approximate number of its clients (Part 1A Item 5.D), its regulatory assets under management (Item 5.F) and, for each private fund it advises, items such as the fund's gross asset value, minimum investment, approximate number of beneficial owners and the percentage owned by the adviser's related persons and by funds of funds (Schedule D Section 7.B.(1)). It does not name the funds' investors.
- **Form D** is the issuer's notice of an exempt offering. It names the issuer's related persons (executive officers, directors and promoters, Item 3), states amounts offered and sold (Item 13) and gives the number of investors (Item 14). It does not identify investors.
- **Form 13F** is filed by institutional investment managers above a reporting threshold (see Form 13F). It reports section 13(f) securities: equity securities on the SEC's Official List of Section 13(f) Securities, mainly US exchange-traded stocks, closed-end fund shares and exchange-traded funds, with certain convertible debt, equity options and warrants. Securities not on the list are not reported, so the form is not a record of private-fund commitments.
- **Supervisory reports** that a manager submits confidentially to a regulator are not open-source information.

Evidence that a particular investor committed to a particular private fund therefore comes from other artefacts: a public body's own records, the investor's or the manager's announcements, or third-party reporting, each with its own origin value.

## 5. Method

The Berkeley Protocol divides an investigation into online inquiries, preliminary assessment, collection, preservation, verification and investigative analysis, followed by reporting. This standard sets rules for what is recorded about each evidence item, for verification and for analysis. It sets no rules for how information is searched for or collected (rule 6.6).

**5.1 Write the requirement first.** Each research task records its question, its subjects, the attributes it seeks and its purpose, so that the evidence can be tested against the question it was gathered to answer.

**5.2 Record each evidence item.** The provenance record of each evidence item holds, as the Evidence & Provenance Standard requires:

1. the web address or other identifier of the artefact;
2. the date and time of retrieval;
3. a fixed copy or fingerprint of the artefact sufficient to show later what it said;
4. the collection method, as process metadata (rule 6.2);
5. the rights basis on which the artefact is used (rule 6.6).

For evidence offered in court, the Protocol treats the web address, the page source and a full-page capture as the minimum. This standard does not claim that evidentiary purpose (section 12).

**5.3 Keep captured copies unaltered.** Where a fixed copy is kept, it is not altered; analysis uses separate working copies. A captured copy remains evidence of what the source said at the time of capture, even if the source later changes or disappears.

**5.4 Verify the source, the item and the content.**

1. **Source analysis.** Attribute the item to its original source and locate the first copy found. Assess the source's credibility from its record and history. Assess its independence and impartiality: its affiliations, its funding and any interest it has in the claim.
2. **Technical analysis of the item.** Establish that the item is what it appears to be. A filing retrieved from the registry's own system is a different item from a copy of it hosted elsewhere. Check metadata, and compare dates inside the document with the page's dates.
3. **Content analysis.** Check internal consistency and consistency with objectively verifiable facts (register entries, dates, amounts). Look for circular reporting, loss of context and misreading.

**5.5 Trace to the originating source and retrieve it.** A news report of a filing is evidence of what the reporter wrote. Its origin is OSINT_SOURCED. When the filing itself is retrieved from the regulator's own system, it becomes a second evidence item with origin REGULATORY_PUBLIC_RECORD. An evidence item names only what the researcher actually read.

**5.6 Record all three evidence dimensions.** Each evidence item carries one origin value (rule 6.1). Each value carries one derivation status (rule 6.3). Each claim carries one validation status with its date (rule 6.4). No value of one dimension is used as a value of another, and no display collapses them into one label.

**5.7 Grade sources and information separately.** The source of each evidence item receives an authority class and a reliability grade (A to F) for the claim type, and the item of information a credibility grade (1 to 6), as defined in the Source Reliability & Confidence Methodology. The Admiralty system requires reliability and credibility to be judged independently. Research on its use finds that raters often assign aligned codes anyway, so each grade is recorded with its reason. A grade is a property of a source or of an item of information. It is not an origin value, and it does not by itself change a claim's validation status. A claim's confidence label (HIGH, MODERATE, LOW, SUSPENDED or UNASSESSED) is assigned under that methodology and is shown separately from its validation status.

**5.8 Keep information and judgment apart.** Following ICD 203, a research output:

1. describes the quality and credibility of its underlying sources and methods;
2. distinguishes information from assumptions and judgments, and states assumptions explicitly where a judgment depends on them;
3. considers alternative explanations where a judgment is uncertain;
4. states whether a judgment is new or changes an earlier one, and why;
5. expresses likelihood with one fixed vocabulary (rule 6.5), and does not combine a likelihood term and a confidence level in the same sentence.

A judgment about what an organisation may do in future is an Altss-defined analytic output. It is labelled as such and is never presented as an observed fact.

**5.9 Document the work.** The work is documented so that it can be reconstructed and questioned. The record of each evidence item states how its value was extracted (manually, automatically, or with the assistance of software including AI models) and, where a person reviewed the extraction, the review and its date. The output of an AI model is never an evidence item.

**5.10 Correct errors openly.** When an error is found it is corrected, and the correction is recorded with its date and reason. Factual corrections and privacy requests are handled independently of any commercial relationship with the person or organisation concerned.

## 6. Classification rules

Rules 6.1 to 6.4 set out the Altss evidence model. It is an Altss-defined methodology, not an industry standard.

**6.1 Evidence origin, per evidence item.** Assigned relative to the claim's subject, by the first rule that matches, in order 1 to 5.

| # | Value | Display label | Rule | Example |
| --- | --- | --- | --- | --- |
| 1 | REGULATORY_PUBLIC_RECORD | Regulatory / public record | A filing to, or a record kept by, a regulator, statutory registry or court, retrieved from that body's own system | A Form D retrieved from EDGAR; a company register entry; an LEI record; a court docket |
| 2 | OFFICIAL_INSTITUTIONAL | Official institutional source | An official publication of a public body or public-sector institution, issued in its official capacity and not as a filing to a regulator | A public pension board's minutes recording a commitment decision |
| 3 | DISCLOSED | Disclosed | Stated by the subject itself, in its own publication or in a statement attributable to it, where rules 1 and 2 do not apply | A manager's press release on its own fund's final close; a statement the subject gave on request |
| 4 | OSINT_SOURCED | OSINT-sourced | Found in a publicly accessible source published by a party other than the subject, where rules 1 to 3 do not apply | A news article; a manager's press release naming an LP, for a claim about the LP |
| 5 | LICENSED_THIRD_PARTY | Licensed / third-party source | Obtained under licence or by private communication from a party other than the subject, and not publicly accessible | A licensed dataset; a non-public document supplied with permission |

Notes on origin:

- Origin is relative to the subject. One manager press release is DISCLOSED for the claim "Fund V held its final close" and OSINT_SOURCED for the claim "Pension Plan X committed to Fund V".
- A filing is still the filer's own account. REGULATORY_PUBLIC_RECORD says where it was filed, not that it is true.
- A claim with several evidence items has several origins. All are shown; none is silently chosen as the best.
- DERIVED and ESTIMATED values have no origin of their own. Their origin is the set of origins of their inputs.

**6.2 Collection method is not origin.** The collection method is recorded separately, with each capture, as process metadata and is never an origin value. Origin follows the artefact: a Form ADV has origin REGULATORY_PUBLIC_RECORD, a news article OSINT_SOURCED and a statement the subject gives in answer to a request DISCLOSED, however each was obtained.

**6.3 Derivation status, per value.**

| Value | Definition | Required provenance |
| --- | --- | --- |
| OBSERVED | The value is stated in a source artefact. | At least one evidence item with a pinpoint |
| DERIVED | The value is computed from observed values by a stated, deterministic rule, including a classification made under a published rule. | The input claims and the rule, with its version |
| ESTIMATED | The value is inferred where no source states it and no deterministic rule produces it. | The method, the inputs and, where possible, a range |

**6.4 Validation status, per claim, as of a date.**

| Value | Definition | Required record |
| --- | --- | --- |
| UNVERIFIED | Held on its evidence as captured, with no independent support and no completed review. The default. | – |
| CORROBORATED | Supported by at least two evidence items whose chains do not share an origin (neither copied from the other nor from a common upstream source), with no unresolved contradiction. | The independent evidence items and the basis for treating them as independent |
| RESEARCH_VALIDATED | A named reviewer completed a deliberate check of the claim against evidence on a recorded date and confirmed it. | Reviewer role, date, evidence examined, outcome |
| CONFLICTING | Two or more evidence items assert incompatible values for the same attribute, under the same qualifier and effective period, and the conflict is unresolved. | The competing claims, handled under section 7 |

Rules:

1. Precedence where several apply: CONFLICTING, then RESEARCH_VALIDATED, then CORROBORATED, then UNVERIFIED. A new contradicting evidence item moves a RESEARCH_VALIDATED claim to CONFLICTING until it is reviewed again.
2. Validation is always stated with its date. It describes the evidence at that date and is not permanent.
3. RESEARCH_VALIDATED can rest on a single source and does not imply CORROBORATED. The number of independent evidence items is recorded separately.
4. For DERIVED and ESTIMATED values, validation covers the inputs and the correct application of the rule or method. Validation never turns an ESTIMATED value into an OBSERVED one.
5. Two values that differ only in definition are different attributes, not a conflict.
6. A subject's filing and the same subject's press release are one originating source for facts only the subject can supply. Together they do not make a claim CORROBORATED (see [triangulation](https://altss.com/glossary/source-triangulation)).

**6.5 Likelihood vocabulary.** Where a research output states how likely an event or development is, it uses these terms and ranges, adopted from ICD 203, and does not mix them with other likelihood words.

| Term | Probability range |
| --- | --- |
| almost no chance | 1–5% |
| very unlikely | 5–20% |
| unlikely | 20–45% |
| roughly even chance | 45–55% |
| likely | 55–80% |
| very likely | 80–95% |
| almost certain | 95–99% |

These ranges express an analyst's judgment. They are not frequencies measured by Altss.

**6.6 Collection and source rights.** This standard does not set collection rules and makes no statement about how any particular artefact was collected. Whether an artefact may be collected and used is a source-rights question, decided before it is used as evidence, under the law that applies and the source's terms. The decision is recorded with the artefact as its rights basis. An artefact without a recorded rights basis is not used as evidence for a published claim, and the collection method is recorded separately from the artefact's origin (sections 6.1 and 6.2).

**6.7 Personal data.** Data-protection laws define personal data differently. Under the EU General Data Protection Regulation (Regulation (EU) 2016/679, text as adopted), personal data means any information relating to an identified or identifiable natural person (Article 4(1)). Neither that definition nor the exclusions from the Regulation's material scope (Article 2(2)) makes an exception for information that is publicly available or that concerns a person in a working role, and Article 14 sets out the information to be given where personal data were not obtained from the person, including whether they came from publicly accessible sources (Article 14(2)(f)). Other laws draw the line elsewhere: the California Consumer Privacy Act excludes publicly available information from its definition of personal information (California Civil Code section 1798.140(v)(2)). Because these laws differ, this standard sets general rules, without replacing jurisdiction-specific legal review:

1. A claim about a person is held to the same evidence rules as any other claim: it carries its evidence items, origin, derivation status and validation status.
2. Requests to correct or remove personal information are handled under the applicable law and independently of any commercial relationship.
3. Which law applies, and what it requires, is a question for counsel in each jurisdiction. Beyond the definitions cited above, this standard does not summarise any data-protection law.

## 7. Conflict handling

**7.1 Test whether the conflict is real.** Before two claims are treated as conflicting, they are checked for the same subject, the same definition, the same as-of date, the same unit and scale, and independent origins, as set out in the Evidence & Provenance Standard. Most apparent conflicts become two correctly qualified claims.

**7.2 Collapse circular reporting.** Several reports that trace to one origin form one evidence chain. They can neither corroborate one another nor outvote an independent source.

**7.3 Record a real conflict.** Where a conflict survives the checks, the claim is CONFLICTING and its confidence label is SUSPENDED. Both claims are kept with their evidence. Any preference between them follows the order in the Source Reliability & Confidence Methodology: authority for the claim type, proximity to the origin, independent corroboration, specificity, then source reliability. Values are never averaged, and a later publication does not prevail merely because it is later when both state the same as-of date.

**7.4 Disappearance is not contradiction.** A source that stops stating a claim (a name removed from a team page) shows that the source changed. It closes the claim's last-observed date and may prompt a recheck. It does not by itself establish that the fact ended.

**7.5 Reviewer disagreement.** Where two reviewers disagree about a grade or a validation status, both views and their reasons are recorded and a third review decides. The record shows who decided.

## 8. Confidence and limitations

- Open sources are uneven. Organisations that publish more about themselves are better documented than those that publish little, and the Protocol warns about the uneven nature of online information. An absence of evidence supports NOT FOUND for the sources and date searched. It never supports a claim that something does not exist.
- Filings are the filers' own accounts. A body's acceptance of a filing does not by itself establish that its content is true; for Form ADV the SEC states that accepting the form is not a finding that it was completed correctly.
- Corroboration depends on identifying origins correctly. A hidden common origin can make dependent reports look independent.
- Reliability and credibility grades are judgments. Irwin and Mandel (2019) argue that the Admiralty-style scales mask subjectivity and recommend numeric probability estimates and periodic re-evaluation. This standard keeps ordinal grades for sources and information, requires reasons for each, and uses numeric ranges for likelihood judgments.
- A capture shows what a source said when it was captured, and nothing about earlier or later versions.
- Source rights limit what can be evidenced. A fact stated only in artefacts without a recorded rights basis has no evidence for a published claim (rule 6.6).
- This standard describes required conduct. It is not a statement about the coverage, timeliness or accuracy of any Altss record.

## 9. Temporal rules

1. Every evidence item records its capture date and time, the artefact's own publication or filing date, and the as-of date of the value, using the date vocabulary of the Evidence & Provenance Standard. These dates are never substituted for one another.
2. The date of the first copy found records when that copy was located and what date it bears. It is not presented as the date the information originated.
3. A copy retrieved from a public web archive carries the archive's capture time.
4. Validation status is always stated with the date it was assigned. A RESEARCH_VALIDATED status carries the date of the review (the "entity verified" date).
5. When a source changes, the earlier capture remains evidence of what it said, and the claim's last-observed date is updated. Review horizons are set by the Temporal Data & Freshness Methodology.
6. External standards cited here are dated: the Berkeley Protocol was launched on 2 December 2020, with a printed United Nations edition in 2022; ICD 203 was signed on 2 January 2015; the text published by ODNI carries technical amendments signed on 21 January 2022 and 12 June 2023.

## 10. Edge cases

- **A subscription publication.** A paywalled article that any member of the public can buy is open-source information under the Protocol's definition. Its origin is OSINT_SOURCED, or DISCLOSED where the subject is the publisher. Whether it may be used as evidence is decided under rule 6.6.
- **A professional profile published by the person.** For a claim about the person, made by that person, its origin is DISCLOSED. For a claim about the person's employer, its origin is OSINT_SOURCED.
- **A copy of a filing hosted by an aggregator.** It is OSINT_SOURCED until the filing is retrieved from the regulator's or registry's own system.
- **A statement on request.** In the Protocol's terms, asking a person for information is closed-source collection. The subject's answer is DISCLOSED and is recorded with the communication.
- **A document from a counterparty under a confidentiality agreement.** LICENSED_THIRD_PARTY. It is not open-source information and is not cited publicly unless the agreement allows.
- **A translation.** A translation is a derivative of the original. The original is captured and cited; the translation used is noted.
- **Search-engine snippets and AI-generated summaries.** Not evidence. The originating source they point to is located, captured and cited instead.
- **Deleted content.** A copy held by a public web archive is evidence of what the page said at the archive's capture time. Its origin follows rule 6.1: an archived copy of the subject's own page stays DISCLOSED, and an archived copy of a third party's page is OSINT_SOURCED.
- **Leaked or hacked material.** The Protocol notes that information made public without its owner's consent is technically open source but may carry legal and ethical restrictions on its use. Whether it may be used is decided under rule 6.6.
- **A source that later blocks access.** A capture made before the block remains evidence of what the source said when it was captured. Whether it may still be used is decided under rule 6.6.

## 11. Worked examples

All names are fictitious.

**Example 1: a fund commitment, recorded in full.** Claim: "Example County Pension committed USD 50 million to Example Buyout Fund IV."

| Evidence item | Origin (relative to the pension) | Authority class | Reliability grade |
| --- | --- | --- | --- |
| E1: Example Capital's press release on the fund's first close, naming the pension and the amount | OSINT_SOURCED | DIRECT_ACCESS (party to the commitment) | B |
| E2: the pension's published annual investment report, listing a USD 50 million commitment to Fund IV | OFFICIAL_INSTITUTIONAL | RECORD_KEEPER (the pension's own acts) | A |

The value is OBSERVED in both. The two items have different originating sources, the manager and the pension, and neither copied the other, so the claim is **CORROBORATED** as of the date the later item was captured, and its credibility grade is 1. After a researcher checks both items against the claim and records the review, its status is **RESEARCH_VALIDATED** as of the review date, and the record still notes two independent evidence items. Board minutes approving the commitment, if published, support a separate claim about the decision, dated to the meeting.

**Example 2: a report of a filing.** A trade article says "Example Fund IV's Form D shows USD 400 million raised from family offices." The researcher retrieves the Form D from EDGAR. It reports the total amount sold (Item 13) and the number of investors (Item 14), and names no investors. The claim splits in two. "USD 400 million sold, as of the filing date" is OBSERVED with origin REGULATORY_PUBLIC_RECORD. "Raised from family offices" rests only on the article: OSINT_SOURCED, UNVERIFIED, with content analysis recording that the filing cannot support it.

**Example 3: circular reporting.** Four articles and three directory profiles state that Example Family Office hired a new CIO. Source analysis finds that every one traces to the office's own announcement, the first copy found. There is one originating source, the announcement (evidence origin DISCLOSED); the articles and profiles are OSINT_SOURCED copies of it. Seven documents do not make the claim CORROBORATED; it is UNVERIFIED until an evidence item from an independent originating source is found or a reviewer validates it.

**Example 4: an attribute no usable source states.** A person's current title is not stated in any artefact with a recorded rights basis. The researcher checks other sources: the employer's own team page and, where the person is a registered investment adviser representative, the SEC's public adviser records. If none states the title, the attribute is recorded as NOT FOUND for the sources and date searched, or UNKNOWN if no search was made.

**Example 5: separating information from judgment.**

- Information: "The June 2026 minutes of Example University Endowment's investment committee record approval of a revised policy portfolio with a 5% private credit target." (OFFICIAL_INSTITUTIONAL, OBSERVED.)
- Assumption: "The endowment will implement the target through fund commitments rather than direct lending."
- Judgment, labelled as an Altss analytic output: "It is likely (55–80%) that the endowment makes at least one new private credit fund commitment within twelve months. This judgment depends on the assumption above."
- Not acceptable: "We have high confidence the endowment will very likely commit soon." It combines a confidence level with a likelihood term, uses an undefined period and does not state its assumption.

**Example 6: one press release, two origins.** A manager announces: "Fund V held its final close at USD 1.2 billion, with commitments from Pension Plan A and Insurer B." For "Fund V's final close was USD 1.2 billion" the subject is the manager's own fund: DISCLOSED. For "Pension Plan A committed to Fund V" the subject is the pension plan: OSINT_SOURCED. Each claim is recorded with its own origin from the same artefact.

## 12. External references

**Berkeley Protocol on Digital Open Source Investigations (OHCHR and UC Berkeley Human Rights Center; launched 2020, printed edition 2022).**

| Protocol element | Where this standard applies it |
| --- | --- |
| Definition of open-source and closed-source information | 3, 10 |
| Professional principles: accountability through documentation | 5.2, 5.9 |
| Methodological principles: accuracy; preservation | 5.3, 5.4 |
| Ethical principles: humility (correcting errors); independence (avoiding conflicts of interest) | 5.10 |
| Legal framework: privacy and data protection; terms of service | 6.6, 6.7 |
| Investigation process: verification (source, technical and content analysis) and investigative analysis | 5.4–5.8 |

Where this standard differs: the Protocol was written for investigations into violations of international criminal, human rights and humanitarian law, with evidence that may be used in court. This standard applies the same discipline to commercial research and does not claim the Protocol's evidentiary purpose. It does not adopt the Protocol's guidance on searching, monitoring and collection: whether an artefact may be collected and used is recorded as a source-rights question (6.6). It adds the Altss evidence model (origin, derivation, validation), which the Protocol does not define.

**ICD 203, Analytic Standards (ODNI; signed 2015, with later technical amendments).** This standard adopts the tradecraft standards on describing source quality and credibility, expressing uncertainty, distinguishing information from assumptions and judgments, analysing alternatives and explaining changes in judgments, together with the likelihood terms and ranges (6.5) and the rule against combining confidence and likelihood in one sentence. It does not adopt the remaining tradecraft standards (customer relevance, argumentation, accuracy of judgments and visual presentation in intelligence products) as rules of this standard.

**Admiralty / NATO grading.** The two-scale system was developed by the British Admiralty's Naval Intelligence Division in the Second World War and is also called the Admiralty Code or NATO system. It rates source reliability A to F and information credibility 1 to 6, and requires the two to be evaluated independently (Kelly, Budescu, Dhami and Mandel, 2025). Irwin and Mandel (2019) review its limitations. The grades, with the Altss-defined authority classes and confidence labels, are set out in the Source Reliability & Confidence Methodology.

**ODNI, IC OSINT Strategy 2024–2026.** Source of the general definition of OSINT used in section 3, and of its attention to the provenance and validity of open-source information.

**W3C PROV-O.** The provenance record that this standard populates is aligned with PROV-O through the Evidence & Provenance Standard.

**Not adopted.** The earlier page at this address described a five- or six-phase "intelligence cycle" and attributed it to NATO without a source. This standard does not use an intelligence cycle; it follows the Protocol's investigation process.

**Data protection.** Rule 6.7 cites the EU GDPR (Articles 2(2), 4(1) and 14(2)(f), text as adopted) and the California Consumer Privacy Act (Civil Code section 1798.140(v)(2)) only to show that definitions of personal data differ. No data-protection law is otherwise summarised.

## 13. Version and change log

- **Version 1.2.0 (2026-10-02).** Specialist review of the legal statements against their primary sources. Rule 6.7 now names the laws it describes: the EU GDPR definition of personal data, which has no exception for publicly available or work-role information, and the California Consumer Privacy Act exclusion of publicly available information. Section 12 updated to match. Filing descriptions in 4.1, 4.2 and 8 verified without change.
- **Version 1.1.0 (2026-10-01).** Independent review. Removed the remaining collection rules and statements about collection practice; the record kept for each evidence item now matches the Evidence & Provenance Standard; grading names the authority classes and confidence labels of the Source Reliability & Confidence Methodology, and an unresolved conflict is labelled SUSPENDED; Example 1 no longer treats a board approval as evidence of a commitment and gives one credibility grade to a corroborated claim; Example 3 separates the originating source from the evidence origin; the Form 13F reporting threshold is left to the Form 13F concept page; ICD 203 amendment dates and dash characters corrected.
- **Version 1.0.0 (2026-10-01).** Rewrite and retitle of "The OSINT Intelligence Framework for Private Markets Fundraising", keeping its address. Removed: all product figures and claims (source and jurisdiction counts, signal latency, refresh cycles, deliverability targets, contact and coverage counts, platform conversion figures), unsourced contact-decay statistics and decision-timeline figures, the fundraising targeting workflow (moved to the LP Targeting & Prioritization Guide), entity resolution by name and address similarity (replaced by the Entity Resolution Methodology), an unsourced intelligence-cycle attribution, a grading table that rated whole filing types "completely reliable", descriptions of Forms ADV, D and 13F and of confidential supervisory reporting as sources of investor identities, and a legal section that misstated several privacy laws. Added: the Berkeley Protocol-aligned process, capture and verification rules, the three-dimension evidence model with origin separate from collection method, the ICD 203 language rules and likelihood terms, the source-rights rule and the general position on personal data.

**Change control.** Changes to the origin values, the validation statuses, the source-rights rule in 6.6 or the personal-data rules in 6.7 are major changes. New examples and clarifications are minor changes.

## Concepts used

- [Open-Source Intelligence (OSINT)](https://altss.com/glossary/osint)
- [Source Reliability](https://altss.com/glossary/source-reliability)
- [Triangulation (Source Triangulation)](https://altss.com/glossary/source-triangulation)
- [Primary Source](https://altss.com/glossary/primary-source)
- Secondary Source
- Public Record
- Regulatory Filing
- Evidence Chain
- [Data Provenance](https://altss.com/glossary/data-provenance)
- [Evidence Dates](https://altss.com/glossary/evidence-dates)
- Observed, Derived and Estimated Data
- Negative Evidence
- Source Conflict
- Human-in-the-Loop Validation
- [Form ADV](https://altss.com/glossary/form-adv)
- [Form D](https://altss.com/glossary/form-d)
- Form 13F

## Sources

1. [Berkeley Protocol on Digital Open Source Investigations](https://humanrights.berkeley.edu/publications/berkeley-protocol-on-digital-open-source-investigations/). OHCHR; Human Rights Center, UC Berkeley School of Law, United Nations (OHCHR) and UC Berkeley, HR/PUB/20/2; launched 2 December 2020; printed edition (c) 2022 United Nations. Status: Current (checked 2026-10-01). Introduction (investigation steps); Ch. I.C para 14 (open vs closed source; leaked or hacked material); Ch. II paras 25-26, 30, 32, 35-37 (principles; para 36 uneven online information); Ch. III.E paras 61-62 (privacy and data protection) and III.F para 65 (terms of service); Ch. VI paras 153, 155, 168-169, 176-180, 183-184, 187 (collection defined, capture minimum, evidentiary and working copies, verification)
2. [Intelligence Community Directive 203: Analytic Standards](https://archive.dni.gov/files/documents/ICD/ICD-203.pdf). Office of the Director of National Intelligence, ODNI, Signed 2 January 2015; technical amendments incl. 21 January 2022. Status: In force (as amended) (checked 2026-10-01). Section D.6.e(1)-(4), (7); D.6.e(2)(a) likelihood table; D.6.e(2)(b); D.6.e(3) definitions; technical amendment pages (signed 12 June 2023 and 21 January 2022)
3. [The effect of source reliability and information credibility on judgments of information quality in intelligence analysis](https://doi.org/10.1017/jdm.2025.10007). Megan O. Kelly; David V. Budescu; Mandeep K. Dhami; David R. Mandel, Judgment and Decision Making (Cambridge University Press), Vol. 20, e36 (2025); open access, CC BY. Status: Published (checked 2026-10-01). Introduction; Table 1
4. [Improving information evaluation for intelligence production](https://doi.org/10.1080/02684527.2019.1569343). Daniel Irwin; David R. Mandel, Intelligence and National Security, Vol. 34(4), pp. 503-525. Status: Published (paywalled) (checked 2026-10-01). Vol. 34(4), pp. 503-525; discussion and recommendations
5. [The INT of First Resort: Unlocking the Value of OSINT - The IC OSINT Strategy 2024-2026](https://www.dni.gov/files/ODNI/documents/IC_OSINT_Strategy.pdf). Office of the Director of National Intelligence, ODNI, Strategy covering 2024-2026; foreword by DNI Avril D. Haines. Status: Current strategy period (checked 2026-10-01). p.1 definition; p.2 introduction
6. [Form ADV (Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers) - SEC form cover and index](https://www.sec.gov/about/forms/formadv.pdf). U.S. Securities and Exchange Commission, OMB No. 3235-0049; expires 2027-07-31. Status: in force (checked 2026-10-01). Index page, 'SEC's Collection of Information'
7. [Form ADV Part 1A (paper version) - Uniform Application for Investment Adviser Registration and Report by Exempt Reporting Advisers](https://www.sec.gov/about/forms/formadv-part1a.pdf). U.S. Securities and Exchange Commission, SEC 1707 (07-24). Status: in force (checked 2026-10-01). Item 5.D; Item 5.F; Schedule D Section 7.B.(1) items 11-15
8. [Form D - Notice of Exempt Offering of Securities (form and instructions, paper version)](https://www.sec.gov/files/formd.pdf). U.S. Securities and Exchange Commission, SEC1972 (5/17); OMB No. 3235-0076, expires 2027-07-31. Status: in force (checked 2026-10-01). Items 3, 13, 14
9. [17 CFR 240.13f-1 - Reporting by institutional investment managers of information with respect to accounts over which they exercise investment discretion (Form 13F)](https://www.law.cornell.edu/cfr/text/17/240.13f-1). U.S. Securities and Exchange Commission (CFR text via eCFR; LII mirror), eCFR current as of 2026-09-29; no substantive amendment since eCFR baseline. Status: in force (checked 2026-10-01). 240.13f-1(c)
10. [Frequently Asked Questions About Form 13F](https://www.sec.gov/rules-regulations/staff-guidance/division-investment-management-frequently-asked-questions/frequently-asked-questions-about-form-13f). U.S. Securities and Exchange Commission, Division of Investment Management (staff), Last updated 2026-09-28. Status: current (checked 2026-10-01). Question 7 (Section 13(f) securities)
11. [Investment Adviser Public Disclosure (IAPD)](https://adviserinfo.sec.gov/). U.S. Securities and Exchange Commission, Live database (accessed 2026-10-01). Status: current (checked 2026-10-01). Firm and individual search pages (accessed 2026-10-01)
12. [Introducing the Legal Entity Identifier (LEI)](https://www.gleif.org/en/about-lei/introducing-the-legal-entity-identifier-lei). GLEIF, Global Legal Entity Identifier Foundation, ISO 17442 identifier; web page accessed 2026-10-01. Status: Current (checked 2026-10-01). 'Introducing the LEI' page: each LEI identifies exactly one legal entity
13. [PROV-O: The PROV Ontology](https://www.w3.org/TR/prov-o/). Timothy Lebo; Satya Sahoo; Deborah McGuinness (eds.), W3C, W3C Recommendation, 30 April 2013. Status: Current Recommendation (checked 2026-10-01). W3C Recommendation of 30 April 2013, starting-point classes Entity, Activity, Agent
14. [Regulation (EU) 2016/679 (General Data Protection Regulation), text as adopted](https://www.legislation.gov.uk/eur/2016/679/contents/adopted). European Parliament and Council of the European Union (EU original text via legislation.gov.uk, 'adopted' version), Adopted 27 April 2016 (OJ L 119, 4.5.2016); text as adopted. Status: in force (checked 2026-10-02). Articles 2(2), 4(1), 14(2)(f) (text as adopted)
15. [California Civil Code section 1798.140 (California Consumer Privacy Act, definitions)](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=1798.140). California State Legislature (leginfo.legislature.ca.gov), Amended by Stats. 2025, Ch. 67, Sec. 27 (AB 1170), effective 1 January 2026. Status: in force (checked 2026-10-02). Sec. 1798.140(v)(2)

## Related frameworks

- Standard · Version 1.2

  ### [Altss Evidence & Provenance Standard](https://altss.com/knowledge-center/frameworks/evidence-and-provenance-standard)

  The Altss standard for recording evidence behind private-markets facts: claim-level provenance, evidence chains, three separate evidence dimensions (evidence origin, derivation status, validation status), distinct date types, null states such as unknown vs not disclosed, negative evidence, conflicts and claim citation.
- Methodology · Version 1.2

  ### [Altss Source Reliability & Confidence Methodology](https://altss.com/knowledge-center/frameworks/source-reliability-and-confidence-methodology)

  The Altss methodology for grading sources and assigning confidence labels to private-markets claims: source authority classes, reliability and credibility grades adapted from the NATO Admiralty system, independence, use of validation status, conflict handling, label meaning and limits, calibration and decay.
- Methodology · Version 1.2

  ### [Altss Entity Resolution Methodology](https://altss.com/knowledge-center/frameworks/entity-resolution-methodology)

  The Altss methodology for deciding whether two records describe the same entity: identity, relation and role kept separate; organisations merged only on registry identifiers or a filing naming both as one; similarity creates relation candidates, never merges; no metrics summed across entity families.
- Methodology · Version 1.2

  ### [Altss Temporal Data & Freshness Methodology](https://altss.com/knowledge-center/frameworks/temporal-data-and-freshness-methodology)

  The Altss methodology for time in private-markets data: valid time vs transaction time, point-in-time reconstruction, as-of reporting, freshness as an attribute of each claim rather than a page, decay, and why a content edit never implies that a fact was verified.
- Standard · Version 1.2

  ### [Altss Private Markets Research Citation Standard](https://altss.com/knowledge-center/frameworks/research-citation-standard)

  Altss's rules for citing sources in private-markets reference and research content: source tiers, no self-citation or competitor evidence for general claims, a fixed claim format with unit and as-of date, recency markers, and rules for AI-assisted drafting.
- Standard · Version 1.2.0

  ### [Altss Family Office Classification Standard](https://altss.com/knowledge-center/frameworks/family-office-classification-standard)

  How Altss classifies family offices: the SEC family office rule as a US regulatory exclusion rather than a general definition, accredited-investor family office categories, Altss-defined labels for single-, multi-, embedded and virtual family offices, adjacent types excluded, and the evidence each label requires.

## Canonical URL

https://altss.com/knowledge-center/frameworks/osint-framework-for-private-markets-intelligence