Tiffany George at the FTC recently posted made a blog posting reminding users of their FCRA obligations. Her caution is against “double-dipping”. Meaning that “[i]f [users] get a consumer report for one purpose, [they should not] use it for a different purpose.” The posting also encourages users to review “the Notice to Users of Consumer Reports” and notes that CRAs “are required to give [them] this document to inform [users] of [their] obligations under the FCRA. Other federal or local laws also may apply to…use[rs] of consumer reports.” There is no indication of what, if anything, prompted this blog posting.
Eric J. Ellman is Senior Vice President for Public Policy and Legal Affairs at the Consumer Data Industry Association (CDIA) in Washington, DC. He also served for eight months as Interim President and CEO of the Association. More