Public Sector

Use of Consumer Credit Report – Permissible Purpose

Government agencies are allowed to obtain and use consumer credit data (including a full Consumer Credit Report or data derived from a Consumer Credit Report) when they have a permissible purpose. Permissible purpose is defined in Section 604 of the Fair Credit Reporting Act (FCRA). [15 U.S.C. § 1681b]. Read the applicable text here.

If you have questions related to a possible program or application in which you believe you need a consumer credit report under permissible purpose, please contact Kevin Kottman, Vice President, Public Sector at TransUnion: kevin.kottman@transunion.com or 443-465-7171.

Under the law, government agencies may request a consumer credit report from TransUnion for the following types of purposes:

• Licensing or benefit eligibility: To determine whether an individual qualifies for a government-issued license or benefit, if financial responsibility or status are required to be considered in connection with issuing the license or benefit.

• Investigations: To determine whether to pursue further action against individuals who, for instance, misrepresent their eligibility to receive a license or benefit, or initiate business transactions with the government under false pretenses.

• Credit evaluation: To assess the risk of extending, servicing or investing in credit obligations including extending credit or underwriting insurance.

• Child support enforcement: For state and local agencies purpose of establishing an individual’s capacity to make child support payments, determining the appropriate level of such payments, or enforcing a child support order, award, agreement, or judgment.

• Employment eligibility: Federal, state and local agencies may use credit reports for background checks with the consent of the applicant or employee.

• Other instances where the government agency receives consent from the consumer in writing.

Use of Non-Credit Data

Government agencies are allowed to secure non-credit consumer data (which includes public records and private, proprietary data sources) for various purposes but must comply with specific consumer privacy and data security regulations under the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act (DPPA).

Government agencies have a broad permissible use for DPPA-covered data from TransUnion to carry out government functions.

If you have questions related to a possible program or application in which you believe you need a consumer credit report under permissible purpose, please contact Kevin Kottman, Vice President, Public Sector at TransUnion: kevin.kottman@transunion.com or 443-465-7171.

Government agencies may use GLBA-covered data from TransUnion for the following general purposes:

• Combat fraud: Ability to use certain data to verify and authenticate people who use government services.

• Investigations: Ability to use certain data to investigate suspected criminal activity related to tax collection, entitlement or service fraud, public safety and national security.

• Other instances where the government agency receives consent from the consumer or direction from the consumer to use the data.

• Carrying out most government functions: Ability to maintain accurate records for purposes of preventing and detecting fraud, locating criminals, witnesses, victims, debtors and benefits recipients, and complying with legal obligations placed on government agencies.

Developing Predictive Models

Government agencies are allowed to secure consumer data for the development of predictive data models but must comply with the rules and regulations governing the underlying data. This may be the FCRA (for credit data) and/or the GLBA and DPPA (for non-credit data).

If you have questions related to a possible program or application in which you believe you need a consumer credit report under permissible purpose, please contact Kevin Kottman, Vice President, Public Sector at TransUnion: kevin.kottman@transunion.com or 443-465-7171.

TransUnion offers credit-based (FCRA) solutions and non-credit (GLBA and DPPA) solutions for the following general purposes:

• Identity verification: Ability to use certain data to identify possible identity theft that may put public safety, government infrastructure or government services at risk.

• Identify fraud: Ability to use certain data to predict possible tax, entitlement or benefit fraud.

• Ensure workforce trust: Ability to use certain data to predict possible fraud or security risk.