Situation:
Section 607 of the Fair Credit Reporting Act (FCRA) states that “Every consumer reporting agency shall maintain reasonable procedures that require prospective users of information to identify themselves, certify the purposes for which the information is sought, and certify that the information will be used for no other purpose. Every consumer reporting agency shall make a reasonable effort to verify the identity of a new prospective user and the uses certified by such prospective user prior to furnishing such user a consumer report.”
Organizations handling and selling consumer data must comply with federal laws and regulations to ensure that they are protecting the data they own, manage, and distribute. It is incumbent upon data providers to implement the internal controls necessary to mitigate risk, and a critical internal control is to “know the customer” before passing them consumer data.
Recent media coverage has highlighted a multi-million dollar Federal Trade Commission settlement that one commercial data broker has faced due to a data security breach that was in violation of the FCRA. In order to prevent such data security breaches and associated fines, commercial data brokers and organizations handling consumer data must ensure that reasonable procedures are in place to screen prospective subscribers.
Solution:
Global Compliance provides high quality, cost-effective, on-site physical inspections to validate both business legitimacy and intent. With thousands of inspectors located throughout the United States, Canada, Puerto Rico, Guam and the U.S. Virgin Islands, we can complete inspections within 3-5 days from request for quick turnaround.
Our minimum standard On-Site Verification Service includes:
- Completed standard inspection report form detailing:
- Physical Location - address, type of location, permanency of location, active status of location, types of products/services marketed
- Security - physical security mechanisms, practices for securing and disposing of confidential information
- Interior and exterior digital photographs
- Web-based inspection requests
- Web-based tracking
- Web-based report delivery
Outcome:
On-site inspections reduce risk by improving visibility into the potential customer, thus allowing consumer reporting agencies to comply with federal laws and regulations surrounding data protection, including section 607 of the Fair Credit Reporting Act (FCRA).
|
