A third party that regularly assembles public records, employment history, scores, or similar information for employers may be a consumer reporting agency, and the resulting dossier may be a consumer report. Labels do not decide coverage. The facts and intended use do.
Possible provider duties
Duties may include a permissible purpose, reasonable procedures for maximum possible accuracy, file disclosure, dispute investigation, correction or deletion of inaccurate or unverifiable information, and special procedures for public-record employment reports.
Possible employer duties
Duties may include clear disclosure, written permission, pre-adverse-action notice, a copy of the report and rights summary, time to dispute, and a final adverse-action notice.
Official guidance
CFPB Circular 2024-06 · CFPB employment background-check overview