Office of Human Resources

Verifying Identity in Consumer Reports

Brandeis University is committed to the prevention of identity theft. In furtherance of this commitment and in accordance with rules published by the Federal Trade Commission regarding the duties of users of consumer reports, this policy sets forth procedures for verifying the identity of an individual when the university receives a notice of address discrepancy from a consumer reporting agency.

Applicability

This policy applies to any individual for whom Brandeis receives a consumer report. The term “consumer report” means any written, oral or other communication of any information by a consumer reporting agency bearing on a consumer's credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics or mode of living that is used by the university in making an employment decision or a decision to extend credit. Consumer reports include credit rating analyses and criminal background checks.

Guidelines

When a supervisor or other authorized individual receives a notice of address discrepancy from a consumer reporting agency regarding a consumer report, the supervisor must take steps to reasonably confirm that the consumer report relates to the individual about whom the supervisor requested the report. This may be done by:

  1. Comparing the information in the consumer report provided by the consumer reporting agency with information the university:
    • Obtains and uses to verify the individual’s identity in its normal course of business.
    • Maintains in its records, such as applications, change of address notifications or other account records.
    • Obtains from third-party sources.
  2. Verifying the information in the consumer report provided by the consumer reporting agency with the subject individual. In the event that the supervisor is able to reasonably confirm that the consumer report relates to the subject individual, he/she must take steps to reasonably confirm the correct address for the individual. This may be done by:

    • Verifying the address with the individual about whom he/she has requested the report.

    • Reviewing the university’s records to verify the address of the individual.

    • Verifying the address through third-party sources.

In the event that the supervisor is able to reasonably confirm the correct address for the individual, such manager shall report that address to the consumer reporting agency that furnished the original consumer report.