Choicepoint accountholders (Caveat Research included) received an email yesterday annoucing a variety of changes in the services provided by the information aggregator. Expectedly, given the recent controversy, the majority of the chances effect the presentation and availability of personal details such as full dates of birth and social security numbers.

Choicepoint also provided assurances that they are conducting a thorough review of all account holders to ensure that further data thefts from fraudulent subscribers are prevented.

The Virtual Chase has a good summary of the relevant details.

Combined with Choicepoint's new information access protocols are alterations in its "permissible use" options. For the last several years searching with Choicepoint meant responding to a series of initial questions that serve categorize your search (restricting or accessing data accordingly) in conjunction with the relevant privacy and consumer credit laws. Choicepoint has recently up-dated this interface.

All searches must now be categorized based on allowable uses under the Gramm-Leach-Bliley Act:

To ensure continued compliance with the privacy provisions of the federal Gramm-Leach-Bliley Act, and the subsequent regulations adopted by the Federal Trade Commission ("GLB"), the permissible purpose screens presented as part of the AutoTrackXP log in process have been changed. These industry specific screens contain new language that will now correspond to exceptions under the law.

To maintain compliance with GLB, a user must now select only a single purpose from the presented list. Misrepresenting your access purpose is a violation of our subscriber agreement and federal and state laws. Any use of ChoicePoint information other than for the selected permissible purpose is grounds for account termination and may be referred to the Federal Trade Commission or to the appropriate state investigative agency.

Designated permissible purpose changes can be made at any time after log in by clicking the link marked "PERMISSIBLE USE" on the top of each page.

The "permissable use" options under GLB are:

• For use by a person holding a legal or beneficial interest relating to the consumer.
  

• For use as necessary to effect, administer, or enforce a transaction requested or authorized by the consumer, including location for collection of a delinquent account.
  

• For use in complying with a properly authorized civil, criminal, or regulatory investigation, subpoena, or summons by federal, state, or local authorities.
  

• For use to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.

• For any other use permitted or otherwise not restricted by law and which may reasonably be expected to be part of the normal course and scope of your business or profession.

No doubt given the current climate, these changes are necessary. I do worry that it will make our job harder, as a legitimate corporate investigative firm routinely tasked with assisting in board vetting, due diligence investigations, litigation support and the like. Full dates of birth and social security numbers (when not used for evil) are not just helpful indexing tools for other data but also essential elements in say, conducting a proper criminal background check.

While the investigative community should be supportive of measures designed to ensure that personal data is not misused, this same data is part of what we employ to prevent fraud in other business sectors.

-- MDT

Labels: background checks