Some Historical Background
To pique your interest, the following is a brief history of the rose to illustrate it's association with "Private" Investigations.
In Greek mythology the Rose was created by Chloris, the goddess of flowers, who formed the rose from the body of a nymph that was found one day in a clearing in the woods. Chloris asked Aphrodite, the goddess of love, for help and she gave the rose her beauty; Dionysus, the god of wine, added nectar to give her a sweet scent, and the three Graces gave her charm, brightness and joy. Then Zephyr, the West Wind, blew away the clouds so that Apollo, the sun god, could shine and make the flower bloom and Chloris crowned the rose as queen of the flowers.
Aphrodite presented a rose to her son Eros (Cupid), the god of love, and the rose became a symbol of love and desire.
Eros (Cupid) gave the rose to Harpocrates, the god of silence, to induce him not to gossip about his mother's amorous indiscretions. Thus the rose also became the emblem of silence and secrecy.
In the middle ages a rose was suspended from the ceiling of a council chamber, pledging all present to secrecy, or Sub Rosa, "under the rose".
Since Roman times the rose has been a symbol of secrecy. The fourth century Christian writer, Gregory Naziansen, wrote, "Like the rose in spring hidden in its bud, so must the mouth be closed and restrained with strong reins, enforcing silence to loquacious lips." So roses were painted over church confessional boxes and on the ceilings of banqueting rooms. Conversations held "Sub Rosa" ("under the rose") were in strictest confidence.
Today, the term Sub Rosa refers to the clandestine surveillance of an individual's daily activities, documenting these activities with the aid of video or still cameras.
Sub Rosa video is often the most valuable tool available when evaluating a wide array of legal issues; discretely obtained, videotaped documentation of an individual's activities, associations, and/or income related endeavors.
Most claims of a physical injury, its limitations, restrictions, and/or the true extents of the alleged injury are subjective and generally involve "soft tissue" injuries. As such, subjective claims are open to interpretation by doctors, lawyers, claims handlers, and adjudicators as well.
Insurance Companies, Third Party Administrators, and Self Insurers alike employ the Sub Rosa investigation to examine claims made by injured persons, across many lines, i.e. Workers' Compensation, Liability, Disability, Life and Health, as well as, Income Protection Plans (Private & ERISA PLANS).
Within the arena of Insurance, Sub Rosa investigations are routinely utilized to obtain information to better evaluate the claimed injury and resulting effects on the person's daily activities. Doctors, lawyers, and claims professionals review the documentation, collaborate, and render decisions to formulate a plan of action.
Remember, documentation obtained during a Sub Rosa investigation can also be open to interpretation, especially if the investigator fails to document the individual's activities from start to finish, i.e. walking, bending, climbing, lifting, and so on.
A claims handler may suspect exaggeration and/or fraud, but if a full and complete picture is not presented, the doctor, defense attorney, referee, or Judge could assume, assert, and even conclude there is no substantial proof the claim has been exaggerated, let alone that fraud exists.
People, who become injured, are just that, People, and the human factor involved in describing one's own pain, limitations, and/or restrictions, as well as, how their specific injury may impede their ADL's [Activities of Daily Living] is unique to the individual; the rest of us can only make an informed decision based on the information available.
A successful Sub Rosa investigation occurs when the documentation clearly refutes the individual's "self-stated" restrictions and/or limitations. For example, an individual states that, due to an injury, he/she cannot bend, climb stairs, walk, drive, or work.
Sub Rosa video of an individual consistently performing activities outside his/her stated restrictions/limitations can be invaluable in the prosecution of Criminal Insurance Fraud. However, even if fraud is not an issue, the documentation can still be a useful tool when used by a physician conducting an IME, AME, or QME charged with evaluating the degree of an individual's disability.
Some Practical Background
Many of these claims have not raised any red flags to warrant this type of action. Injured workers in even the most innocuous of occupations such as teachers and librarians, are having their everyday activities recorded on video for the insurance carriers to use against them in court to attempt to invalidate their claims. More and more we are seeing school districts and city municipalities resorting to these sordid tactics.
In a standard interpretation of the law, private investigators may only photograph private people in their private residences, when they are clearly visable to the general public and there is no expectation of privacy. They may not enter onto private property or maneuver themselves into posititons that would allow them unique views that would be otherwise blocked from public view, such as peering or taking pictures thru or over backyard fences.
That brings to mind the story told to us by a Southern California female injured worker who was recuperating from recent lower back surgery and was progressing quite well with her physical therapy when her Workers Compensation attorney was sent a subrosa video that was just appalling and a shock to the senses.
The insurance company claims examiner had a private investigators' video of the injured worker having sexual relations with her husband for the first time in almost a year since her surgery. Her doctor thought that the exercise to her back might do her some good and gave his approval. Apparently the video was shot thru her bedroom window by the private investigator standing just outside, with his camera lens pressed against the window glass.
The unusual part about this case is that she and her husband lived in a gated community which meant the investigator had to trespass on their property to get that special video byte. And the defense attorney was quite visably upset when the Workers Compensation judge threw out the video as the fruit of the poison tree. Luckily, justice prevailed in this instance, but it doesn't always find the light of day in many cases as different judges will interpret the law in different ways.
And then there was the recent story of a California schoolteacher who had an uninvited guest at her invitation only wedding. It was a Workers Compensation claims investigator for the local school district where she worked, who later followed her and her new husband while they were on their honeymoon, and videotaped the blushing bride with a high-powered telephoto lens while she sunbathed on a hotel room balcony of the honeymoon suite.
But this injured worker isn't taking this lying down. She and her attorney have filed several civil lawsuits against the School Insurance Progam for Employees (SIPE), a joint powers authority that is a group self-insurer for local school districts in the San Luis Obispo area. Her suit also names Workers' Compensation Administrators, a Santa Maria third-party administrator and Eyecon Investigators as defendants.
These are classic examples of how some private investigators interpret the law, and the extents that they will go to, to get that special shot for their clients, even if they have to violate the law.
Sections 7512-7574 of the California Business & Professions Code, are considered the California Private Investigators Act, and cover the conduct of California Private Investigators.
Below, for your convenience, are excerpts from the California Civil Code that deal with Invasion of Privacy and Stalking. Read them well and KNOW your rights. 
(a) A person is liable for physical invasion of privacy when the defendant knowingly enters onto the land of another person without permission or otherwise committed a trespass in order to physically invade the privacy of the plaintiff with the intent to capture any type of visual image, sound recording, or other physical impression of the plaintiff engaging in a personal or familial activity and the physical invasion occurs in a manner that is offensive to a reasonable person. 
(a) A person is liable for the tort of stalking when the plaintiff proves all of the following elements of the tort:
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