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Operator privacy and hiring

Can a Trust ID be used for hiring decisions?

Do not treat a Trust ID or TrustScore as an automatic hiring or rejection instruction. If a third-party report about an operator is used for employment, promotion, reassignment, retention, or a closely related worker decision, the Fair Credit Reporting Act and state or local laws may apply.

Before use

Identify the lawful purpose, determine whether the report and provider fall under the FCRA, obtain required written permission, use relevant and accurate information, and avoid discrimination.

Before adverse action

Where the FCRA applies, the employer generally must provide required pre-adverse-action information, including a copy of the report and rights notice, allow a meaningful chance to dispute, and provide the required final notice.

Official guidance

CFPB Circular 2024-06 · EEOC and FTC background-check guidance

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