Case study: FTC Warns Mobile Apps can be subject to FCRA
Key point:
Mobile apps that contain the types of information used in employment and tenant screening (for example, criminal record histories) may be ‘consumer reporting agencies’ (CRAs) subject to FCRA
The Fair Credit Reporting Act (FCRA) is a US federal law that limits the use and disclosure of ‘consumer reports’. The FCRA is designed to protect the privacy of consumer report information and ensure that the information supplied is accurate. Consumer reports are communications that include information on an individual’s character, reputation, or personal characteristics and are used or expected to be used for purposes such as employment, housing or credit.
See, Golden Data Article: What is a ‘consumer report’?
On 2012, the Federal Trade Commission (FTC) warned marketers of six mobile applications that provide background screening apps that they may be violating the FCRA if they have reason to believe the background reports they provide are being used for employment screening, housing, credit, or other similar purposes.
The companies that received the letters are:
- Everify, Inc., marketer of the Police Records app,
- InfoPay, Inc., marketer of the Criminal Pages app, and
