What is PII?
PII stands for Personal Identifiable information. A new trend amongst courts is the redaction of PII from their public viewable records. States such as California and Michigan are the leading the way with this trend, and more states and courts are expected to join. Why are they redacting PII? States have taken to redacting this information for the protection of consumers. They are redacting information such as Date of Birth, and driver’s license numbers.
What does this mean for our clients? Delays can be expected in the states where redaction has begun. The federal law requires at least two identifiers to apply a record to an applicant. We require all of our clients to have a consent form from their applicants, and this consent will be of great value in the process of marrying records to the appropriate applicants. Having applicants provide additional identifiers, such as middle names and middle initials is also encouraged. We advocate the inclusion of social traces on reports for all applicants, as this may provide additional identifiers not previously disclosed on the release form.
How is Research Services handling these new rules? We are committed to staying FCRA compliant, and we will continue to have researchers work directly with the courts to verify with uncertainty that a record pertains to an applicant. We will continue to ensure more than one identifier is available before applying it to an applicant. We suggest our clients consider these delays when submitting a report for an applicant located in one of these states, as this will require additional effort on our end, and we will be at the liberty of the court clerks. We will remain alert and educated on any additional states that may begin the redaction process.