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The Ultimate Matching Game of Personal Identifiers

By Keoki Huffman

One of the most prominent requirements of the Fair Credit Reporting Act is that consumer reporting agencies must ensure maximum possible accuracy. The Bureau of Consumer Financial Protection (BCFP) recently released an advisory to shine a light on the industry-wide issue regarding discrepancies in reporting because of inadequate matching procedures. These inaccuracies have become rather frequent over the past decade. 

Rising Inaccuracies in Consumer Reports

Ten years ago, the Federal Trade Commission (FTC) released that one in five consumers that participated in their study had an error on at least one of their three nationwide credit reports. The BCFB has reported that the majority percentage of consumer complaints received have been regarding incorrect information on the individual’s report and just in 2020, companies presented over 191,000 such complaints. 

The information must be accurately assigned, or “matched” to the individual undergoing the background screening using public data. Imprecisions in reports can be attributed to mistakes made during the matching process. A once traditional method of matching, using name-only personal identifiers, particularly has been linked as a leading cause to some of these identified errors. 

Eliminating Name-Only Matching

The BCFP and the Federal Trade Commission are in agreement that name-only matching no longer provides maximum possible accuracy, and therefore, should not be considered in compliance with the FCRA.

For example, there are over 5.5 million people in the United States with the first name James and almost 3 million people with the last name Smith. Want to guess how many people are named James Smith? 49,203 people in the US share the name, James Smith. 

Due to the commonality of identical first and last name combinations across the nation, it is understandable that associating individual consumer records based exclusively on their name is not an acceptable reporting practice. Without qualified personal identifiers, there is a heightened likelihood of false matches and unreliable results.  Looking at additional elements such as Middle Name, Date of Birth, and Address information can help in narrowing down the potential matches to a specific consumer.

The Professional Background Screening Association (PBSA) listed the following as examples of  major federal crimes that can either be unintentionally missed or incorrectly flagged due to erroneous matching processes: 

  • Identity theft
  • Terroristic threats
  • Drug trafficking
  • Kidnapping
  • Embezzlement
  • Weapon offenses
  • Bomb threats
  • Financial crimes
  • Wire fraud
  • Cybercrimes

Alternatively, on the candidate’s side – a false report can affect an individual’s credit score or insurance rates, and even result in a lost job or potential housing opportunity. Since these decisions are highly impactful on monumental life milestones, it is pertinent that consumer reporting agencies feel confident in the data they are utilizing. Especially after the pandemic, the great resignation, and now the high demand for hiring talent, the pressure for faster turnaround times has increased on top of all the evolving regulations.  

The Scavenger Hunt for Personal Identifiers

States redacting personal identifiers doesn’t make it any easier to find other qualified identifiers which are crucial for accurate identification. State Supreme Courts are passing redaction policies to remove dates of birth before releasing the information publicly. Due to these policies, complete records in states like California and Michigan are becoming increasingly harder to retrieve. 

This is why it is exponentially more important than ever to gather all the information available through full-scope searches. There are a variety of methods and products accessible to aid in the research process. Data vendors can supply records through traditional retrieval such as court runners or through innovative technology that empowers automated retrieval. From there, CRAs have the ability to choose what kind of information they want to search and the vendors will assist in delivering the associated records for the data they need. 

There are a variety of different searches that can be performed; the common types generally include: 

  • Alias and address history – Searches an individual’s previous aliases and residential addresses
  • Criminal database searches – Searches previous federal, state, or county courts for criminal information
  • Court research / criminal records – Searches current federal, state, or county courts for criminal records, warrants, and arrests in a selected, specified location (typically the state or county the individual lives or has lived in)
  • Continuous monitoring – The ongoing search for the most recent criminal information for consistent risk management
  • The list continues…

There is an assortment of product and service offerings to collect all the major details with the ability to acquire a wide range of data from driver history, civil, and eviction history to sex offender registries and security watch lists. 

Through several streams of information, background screeners must broaden their search to find other fundamental identifiers. 

While the candidate’s full name is one of the most important personal identifiers, the date of birth (DOB) follows as a close second. On the upside, DOBs at the state court level, are available in all jurisdictions’ repositories. On the downside, DOBs at the federal court level, are unavailable in the federal record-keeping system (PACER). 

Decision-makers can leverage a plethora of other personal identifiers and people-data solutions to help ensure validity and precision within their final reports. 

Essential Verification Elements for Complete Records

Based on the Health Insurance Portability and Accountability Act Compliance (HIPAA) for regulatory recommendations on personal identifiers, there are 10 top personal identifiers that could be used to assist in confirming candidates. The HIPAA identifiers are all information regarding the medical record or delegated data sets that can be used to identify a person, which include: 

  • Names
  • Current & Previous Addresses
  • Date of Birth
  • Phone numbers
  • Email addresses
  • Social Security numbers
  • Certificate/license numbers
  • Vehicle identifiers and serial numbers, including license plate numbers
  • Biometric identifiers, including finger and voiceprints
  • Full-face photographic images and any comparable image

Obtain Comprehensive Records with Innovative Approaches

The most important takeaway for consumer reporting agencies should be that name-only matching is not an acceptable background check reporting method on its own.  Researchers must look for additional elements, both qualifying and disqualifying, to work towards the maximum possible accuracy standard required by FCRA.  Engaging with the court to confirm non-public information, asking the candidate to validate or supply additional information on any court record, or other innovative approaches will assist in building and confirming a comprehensive report.

Know what data is available; stay up-to-date with data sources and regulations, and pay attention to information that is included in the court-level details.

It is valuable to remember that, invalid data can be as erroneous and detrimental as missing information. Collecting all relevant, accessible data helps narrow the gap where fallacious background information can seep through the cracks. Create a research flow process that consists of conducting several types of criminal and personal information searches for a more well-rounded report.

Background screeners cannot feel confident in their decisions unless they have all of the information. 

Learn how you can find more information using Tessera’s comprehensive suite of products.

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