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FCRA compliance reminder: The Work Number® data cannot be shared

If you're a user of The Work Number®, you already understand the importance of staying in compliance with the Fair Credit Reporting Act. After all, you're asked to declare a "permissible purpose" to gain access to the data – an FCRA requirement.

We require a permissible purpose because it's the law! FCRA compels us to require this step. You must have a "permissible purpose" each time you gain access to data in The Work Number. We also have to be able to document the process and provide the subject individual with information about each and every entity that accessed the data contained on The Work Number.

That also means you can't share the data with your colleagues in other departments. While it's perfectly understandable why you might want to help your colleagues, that's not a legal use of the data. If you're in child support enforcement, for example, and your colleague in TANF wants the same information, that colleague must separately declare a "permissible purpose." If you simply send the data to this colleague, you may find yourself in violation of the FCRA. And if you share the data, we won't know that your colleague in TANF had it. That would mean we won't be able to give the subject individual a complete report on the entities who accessed the information, as required by FCRA.

We hope you are getting the fullest possible benefit in using The Work Number, whether you're qualifying a new client for benefits or searching for unreported income to maintain program integrity, or for any other of the many ways in which agencies can benefit from the data. But please remember: the data you get from The Work Number is yours under the permissible purpose you declared and can't be shared.

If you have any questions please contact us at govinfo@theworknumber.com.

Newsletter: January 2016

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