Credit Header Data

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In the United States, Credit header data refers to a subset of consumer credit report information that includes an individual's name, aliases, birth date, Social Security number, current and prior addresses, and telephone number. It consists of Personally Identifiable Information information contained in a credit report. Credit header data does not include credit score or payment history. This data is regulated under Gramm–Leach–Bliley Act and Fair Credit Reporting Act.

Use

Credit header data is used for identification purposes. This type of data is considered by some to be a foundational element for various products and services aimed at identifying and locating individuals for a range of purposes related to gathering of personally identifiable information. These include locating missing children, tracking down individuals for medical research, and assisting in criminal apprehension and fraud prevention.

While law enforcement has historically gathered information by speaking with witnesses and refrencing public record documents, some law enforcement agencies now use commercial data brokers to obtain information (such as credit header data).

There is ongoing debate as to whether credit header data should be considered a considered consumer report.

Regulatory concerns

The use of credit header data has raised concerns regarding privacy and the potential impact of regulatory measures on the availability and disclosure of such information.

The Securities and Exchange Commission (SEC) proposed a rule to implement Title V of the Gramm-Leach-Bliley Act (GLBA), which aims to protect the privacy of consumer financial information. However, some entities such as ChoicePoint, have expressed apprehension about the rule's broad definition of "nonpublic personal information" and its potential to include credit header data.

Consumer Financial Protection Bureau (CFPB) involvement

The Consumer Financial Protection Bureau (CFPB) has indicated its intention to restrict the sale of personal details from consumer credit reports by data brokers. The agency's focus on "credit header" data is part of a broader effort to regulate data brokers who gather and sell consumer information, often without their knowledge. The CFPB plans to propose new rules under the Fair Credit Reporting Act (FCRA) to limit the use of personal information to specific purposes like credit or employment applications.

Proposed rule changes

The CFPB's proposed rule changes aim to define data brokers that sell consumer data as "consumer reporting agencies," triggering requirements for accuracy and dispute handling. The agency also seeks to clarify whether "credit header data" constitutes a "consumer report," potentially limiting the ability of credit reporting companies to disclose sensitive contact information.

Industry response

Businesses and fraud prevention firms have raised concerns that the new rules could hinder their ability to combat fraud and identity theft. They argue that access to consumer information is necessary for safe and seamless transactions. Organizations like LexisNexis Risk Solutions argue that they rely on credit header data to detect fraudulent activities and assert that restrictions on this data would make their tools less effective.

ChoicePoint's statement

In a comment submitted to the SEC, ChoicePoint (a LexisNexis company) argued that the definition of "nonpublic personal information" should be limited to data that is intrinsically financial in nature, as intended by Congress. The company also suggested that the definition of "publicly available information" be revised to reflect the actual nature of such data and provide a workable rule for financial institutions. ChoicePoint emphasized the importance of credit header data in its operations and the need for clarity in the rule to ensure the flow of information is not hindered by the GLBA.

Advocacy and legal perspectives

Consumer advocates such as ANALYSIS welcomed the CFPB's proposals, emphasizing the need for transparency and accountability in the data broker market. They highlight the risks associated with the sale of personal information, such as the potential for misuse and the infringement of privacy. Legal challenges and new laws are expected to shape the future of data broker regulation as the CFPB continues to call for change.

References

This article "Credit Header Data" is from Wikipedia. The list of its authors can be seen in its historical and/or the page Edithistory:Credit Header Data. Articles copied from Draft Namespace on Wikipedia could be seen on the Draft Namespace of Wikipedia and not main one.

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