Skip tracing
Location Information
- 01
What it is.
The data side of finding a consumer: searching permitted databases and public records to establish a current address and telephone number when the information on the placement file is out of date.
- 02
What the law allows.
Consumer report data may be obtained only for a permissible purpose, and collecting an account is one — obtaining it without one is a federal offense, not a policy matter. Non-public personal information carries GLBA obligations, and pretexting to obtain it is separately prohibited.
15 U.S.C. § 1681b(a)(3)(A) · § 1681b(f) · § 1681q · GLBA § 6821 - 03
How we work inside it.
Searches run against permitted sources under a documented permissible purpose recorded per account. Vendors are held to the same standard we hold ourselves to and are audited. What the search produces is contact data — an address and a telephone number — and nothing about the consumer’s finances is gathered because none of it is needed to place a call.
15 U.S.C. § 1681b(f) · CFPB Bulletin 2016-02 - 04
Why we do it.
Bad contact data is the direct cause of wrong-party contact, and wrong-party contact is how a routine account becomes a complaint against our client. Confirming the person before the conversation is the cheapest compliance control there is.
01 Compliance
Compliance Controls
Permissible purpose documented per account before any consumer report data is obtained
Searches limited to establishing address and telephone number
No financial, medical or asset data gathered for locating purposes
Data vendors contractually bound to the same standard, and audited
Access to search tools role-restricted and logged per user
Results verified before dialing, and a disconnected or reassigned number retired
Any third-party contact made during locating follows the location-information rules
Retention of search results bounded by our schedule and securely destroyed
State-specific data access and privacy restrictions applied
The framework behind these controls, and our licensing and bonding, are on our Compliance page →
02 Limits
What We Never Do
Obtain consumer report data without a documented permissible purpose
Use a false pretext or false identity to obtain information
Disclose the debt to anyone contacted while locating a consumer
Gather financial or asset information under the guise of locating
Use located data for any purpose other than the account it was obtained for
What a consumer can ask us to do — including disputing an account — is on Consumer Rights →
The contact itself is governed separately
Finding a number and using it are two different obligations. What may be said to a third party while confirming a consumer’s whereabouts — and what may never be said — is set out on our Location Information page, and confirming a place of employment is covered on Employment Verification.