Does a recruiting firm have the same background-check duties as an employer buying a report?
The FTC page reviewed here describes the employer’s steps when it obtains a consumer report for employment purposes. It does not establish the duties of a recruiting business that assembles or supplies reports.
If your company is the employer using a report, follow the FTC guidance and check applicable state and local rules. If you provide data or reports, get advice on that activity; this employer guide does not establish reporting-agency duties.2
For insurance, describe what records you collect, who can access them and what service you perform. Ask the insurer which form definitions apply; the FCRA guide says nothing about coverage.2,3
Read the Recruiting and Talent Insurance Buying Guide
Sources and Further Reading for Recruiting and Talent
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