FCRA, GLBA & DPPA notice

Last updated: June 2026

This notice describes the federal and state laws that govern who may use Skip Tracers's services and how those services may be used. It is the most important legal document we publish. Read it before placing an order.

If anything on another page of this site conflicts with this notice, this notice controls.

Plain-language summary

If you read nothing else, read this.

1. Skip Tracers is not a consumer reporting agency. We do not assemble or evaluate consumer information for the purpose of furnishing "consumer reports" as those terms are defined in the federal Fair Credit Reporting Act, 15 U.S.C. § 1681a.

2. Our reports are not consumer reports. They are investigative work product produced from public records, proprietary databases, and other lawfully obtained sources.

3. You may not use our reports for any FCRA-covered purpose. This includes, but is not limited to, employment decisions, tenant screening, credit decisions, insurance underwriting, and the determination of a person's eligibility for any license or other benefit granted by a government agency. The subject's consent does not change this. Consent does not convert our work into FCRA-compliant consumer reporting.

4. Several of our services touch data regulated by the GLBA or the DPPA. You may use those services only if you have a permissible purpose enumerated in the relevant statute, and you must attest to that purpose at checkout.

5. Every order requires a permissible-purpose attestation. Submitting an order without a permissible purpose, or for a prohibited use, may expose you to civil and criminal liability under federal and state law and will expose you to liability to Skip Tracers under our Terms of Service.

If you are not certain whether you have a permissible purpose, do not place an order. Email us at compliance@skip-tracers.com and we will help you make that determination before you spend any money.

1. About this notice

Skip Tracers provides investigative research services to professionals with documented permissible purposes, primarily attorneys, licensed private investigators, debt collectors, process servers, repossession agents, insurance investigators, and judgment creditors.

This notice exists to make three things explicit:

• Who we are, and who we are not, under federal law;
• What you may and may not do with our reports; and
• What you must attest to when you place an order.

This notice is not legal advice. If you are unsure whether your intended use of our services is lawful, consult your own attorney before purchasing.

2. The Fair Credit Reporting Act (FCRA)

2.1 What the FCRA does

The Fair Credit Reporting Act, 15 U.S.C. §§ 1681 et seq., regulates how "consumer reporting agencies" assemble, maintain, and disclose "consumer reports", information bearing on a consumer's creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living, when that information is used or expected to be used for an FCRA "permissible purpose."

FCRA-permissible purposes are listed at 15 U.S.C. § 1681b and include:

• A consumer's written instruction;
• Credit transactions involving the consumer;
• Employment decisions;
• The underwriting of insurance involving the consumer;
• A consumer's eligibility for a license or other government-granted benefit;
• A legitimate business need in connection with a transaction initiated by the consumer; and
• Review or collection of an existing consumer account.

When a report is assembled for any of those purposes, it is a "consumer report," its preparer is a "consumer reporting agency," and the full machinery of the FCRA applies, accuracy procedures, dispute handling, notice to consumers, adverse-action obligations, and personal liability for negligent or willful violations.

2.2 Our position: we are not a CRA

Skip Tracers does not assemble or evaluate consumer information for the purpose of furnishing consumer reports. The reports we deliver are investigative work product intended to support, among other uses, service of process, judgment enforcement, debt collection, fraud investigation, due diligence, and litigation preparation.

We are not a consumer reporting agency under the FCRA, and our reports are not consumer reports. We have no relationship with the three nationwide CRAs (Equifax, Experian, TransUnion) for purposes of furnishing FCRA consumer reports. Where our underlying data providers source so-called "credit-header" information from CRAs, that data is licensed for non-FCRA permissible purposes only, and we pass that restriction through to you.

2.3 What this means for you

You may not use our services, or any data derived from our reports, for any FCRA permissible purpose. In particular, the following uses are prohibited, with or without the subject's consent:

• Employment screening. Do not use our reports to evaluate a person for hire, promotion, reassignment, retention, or any other employment-related decision. Use an FCRA-compliant background screener instead.
• Tenant screening. Do not use our reports to evaluate a person's suitability as a tenant or to make a rental decision. Use an FCRA-compliant tenant screening service instead.
• Credit decisions. Do not use our reports to determine a person's eligibility for credit, the terms of credit, or to verify creditworthiness for an extension of credit.
• Insurance underwriting. Do not use our reports to determine a person's eligibility for insurance, the premium charged, or the terms of an insurance policy.
• Eligibility for licenses or government benefits. Do not use our reports to determine a person's eligibility for any license or other benefit granted by a federal, state, or local government.
• Any other FCRA "permissible purpose" as that term is defined in 15 U.S.C. § 1681b.

Consent does not cure this. A subject's written consent to a "background check" does not authorize you to use our non-FCRA reports in place of an FCRA-compliant consumer report. If you need an FCRA-permissible purpose report, use an FCRA-compliant provider.

2.4 The Criminal & Identity Report, specifically

Our Criminal & Identity Report combines identity verification, criminal and traffic records, civil court records, address history, and known aliases. Because of its content, it is the report most commonly misused for prohibited FCRA purposes.

The Criminal & Identity Report is not an FCRA-compliant consumer report and must not be used for hiring, promotion, retention, tenant screening, credit, insurance, or government-benefit decisions. It is suitable for fraud investigation, due diligence in a non-employment context, litigation preparation, and judgment enforcement. If you require an FCRA-compliant background check for an employment or housing decision, you must obtain it from a consumer reporting agency that operates under the FCRA, we are not such a provider.

3. The Gramm-Leach-Bliley Act (GLBA)

3.1 What the GLBA covers

The Gramm-Leach-Bliley Act, 15 U.S.C. §§ 6801 et seq., restricts the disclosure and reuse of "nonpublic personal information" (NPI) obtained from a financial institution. NPI includes, among other things, a consumer's name, address, telephone number, and Social Security number when that information is collected by a financial institution in connection with a financial product or service. So-called "credit-header" data, the identifying portion of a credit file, is treated as GLBA NPI in many circumstances.

15 U.S.C. § 6802(e) lists the exceptions under which a financial institution may disclose NPI to a non-affiliated third party (and, in turn, under which that party may receive and reuse the data). Among others, these include disclosures:

• To protect the confidentiality or security of records;
• To protect against actual or potential fraud, unauthorized transactions, claims, or other liability;
• For required institutional risk control or for resolving customer disputes or inquiries;
• To persons holding a legal or beneficial interest relating to the consumer;
• To persons acting in a fiduciary or representative capacity on behalf of the consumer;
• To attorneys, accountants, and auditors;
• In compliance with federal, state, or local laws, rules, and other applicable legal requirements;
• To respond to a properly authorized civil, criminal, or regulatory investigation; or
• For investigation on a matter related to public safety.

3.2 Which of our services involve GLBA-regulated data

The following services draw, in whole or in part, on data that is or may be GLBA-regulated NPI:

• Locate Report
• Comprehensive Skip Trace
• Reverse Phone Lookup
• Address History Report
• Email & Social Media Report
• Asset Search (restricted)
• Criminal & Identity Report (restricted)
• Court & Public Records Report (in part)

By ordering any of these services, you represent that your use falls within one of the § 6802(e) exceptions above. If your use does not fall within an exception, you may not place the order, regardless of the subject's consent.

4. The Driver's Privacy Protection Act (DPPA)

4.1 What the DPPA covers

The Driver's Privacy Protection Act, 18 U.S.C. §§ 2721-2725, prohibits the disclosure and reuse of "personal information" obtained from a state motor vehicle record except for an enumerated permissible purpose. Penalties include both civil liability (with actual damages, punitive damages, and attorney's fees) and criminal fines.

18 U.S.C. § 2721(b) lists the permissible uses. The ones most relevant to our customers include:

• Use by a government agency in carrying out its functions;
• Use in connection with matters of motor vehicle or driver safety and theft;
• Use in the normal course of business by a legitimate business to verify accuracy of personal information submitted by an individual, and if such information is incorrect, to obtain the correct information, but only for the purposes of preventing fraud, pursuing legal remedies against, or recovering on a debt or security interest;
• Use in connection with any civil, criminal, administrative, or arbitral proceeding, including service of process, investigation in anticipation of litigation, and the execution or enforcement of judgments and orders;
• Use by an insurer or insurance support organization in connection with claims investigation, antifraud activities, rating, or underwriting;
• Use in providing notice to owners of towed or impounded vehicles; and
• Use by a licensed private investigative agency or licensed security service for any purpose permitted under § 2721(b).

4.2 Which of our services involve DPPA-regulated data

The following services draw on data that is DPPA-regulated and are available only to customers with a permissible purpose under § 2721(b):

• Vehicle Sighting Report (DRN). Sourced from a nationwide license-plate-reader network. DPPA permissible purpose required. You represent at checkout that you hold any license or other professional credential required by applicable law for the stated permissible purpose (for example, a repossession license for a repossession purpose, or a state bar number where the purpose is litigation-related).
• Driving Records Search. Sourced from state DMV records via TLO. DPPA permissible purpose required. You represent at checkout that you hold any license or credential required by applicable law for the stated permissible purpose.
• Motor Vehicle Report (MVR). Official state DMV abstract. DPPA permissible purpose required. State DMVs charge a per-state pass-through fee that we owe whether or not a record is returned; this fee is disclosed at checkout and is non-refundable on no-hit orders. You represent at checkout that you hold any license or credential required by applicable law for the stated permissible purpose.

For all three services, you must select one of the 14 statutory categories listed at 18 U.S.C. § 2721(b) when you place the order. You may optionally upload supporting documentation. We may, in our discretion, request additional documentation, refuse to fulfill an order, or refund without fulfillment if the stated permissible purpose, on its face, does not correspond to one of the § 2721(b) categories.

5. Service-by-service guidance

The following table summarizes the regulatory posture of each service we offer. It is a summary only; the body of this notice controls.

"Restricted" means the service draws on data with heightened legal sensitivity (GLBA, DPPA, or other), and that you represent at checkout that you hold any license or professional credential required by applicable law for your stated permissible purpose.

6. Permissible purpose attestation at intake

Every order placed on Skip Tracers requires you to:

1. Select a permissible purpose from a dropdown at checkout.
2. Describe, in your own words, the specific factual basis for that permissible purpose, for example, the case number, the docket, the matter name, the account in default, or the engagement the work supports.
3. Affirm four certifications: (i) that you have a lawful permissible purpose, (ii) that you understand misuse may violate federal and state law, (iii) that you are not requesting the report for consumer credit, employment, tenant, or insurance eligibility decisions, and (iv) that you are not requesting it for any purpose prohibited by the Acceptable Use Policy, including locating a minor for non-legal purposes, stalking, harassment, or discrimination.
4. Upload supporting documentation. For the two services that draw on Driver's Privacy Protection Act data, Vehicle Sighting Report (DRN) and Driving Records Search, supporting documentation is required before the order can be processed; for all other services it is optional. Acceptable documentation includes a court filing, an attorney engagement letter, an account record, a redacted internal screenshot, or any other evidence of the lawful purpose. We rely on your representation that any documentation is genuine and do not independently authenticate it. For restricted services, you also represent at checkout that you hold any license or credential required by applicable law for the stated permissible purpose.

By submitting the order, you certify under penalty of perjury and federal law that:

• You have read and understood this notice.
• The permissible purpose you selected and described is true and accurate.
• You will use the resulting report only for the stated purpose.
• You will not use the report for any FCRA-covered purpose.
• You are authorized to receive the report on behalf of the entity, if any, that you represent.
• You will not redistribute, resell, or share the report except as necessary to accomplish the stated permissible purpose.
• You understand that material misrepresentations in this attestation may expose you to civil and criminal liability and will expose you to liability to Skip Tracers under our Terms of Service.

We retain attestation records as part of our compliance program for the period described in our Privacy Policy.

7. Audit and verification

We reserve the right, before or after fulfillment of any order, to:

• Request additional documentation in support of your permissible purpose.
• Decline to fulfill an order if the stated purpose on its face does not appear to be a permissible use under the FCRA, GLBA, DPPA, or other applicable law.
• Refund the order and decline service without explanation.

We do not provide refunds for orders cancelled because the customer cannot or will not substantiate the attestation. See the Terms of Service for refund details in all other cases.

8. Consequences of misuse

Misuse of our services, whether by providing a false attestation, exceeding the scope of a permissible purpose, or using a report for a prohibited purpose, may result in:

• Immediate account or order suspension and refusal of future service.
• Disgorgement of any fees paid and recovery of Skip Tracers's investigative, legal, and compliance costs.
• Civil liability under the FCRA, GLBA, DPPA, FDCPA, state privacy statutes, and consumer-protection statutes, which may include actual damages, statutory damages, punitive damages, attorney's fees, and costs.
• Criminal liability under federal law, including (where applicable) penalties under the FCRA (15 U.S.C. § 1681q), the DPPA (18 U.S.C. § 2723), and federal wire-fraud statutes.
• Referral to law enforcement and to professional licensing authorities where applicable (state bar, PI licensing board, repossession licensing authority).
• Notification to affected subjects where required by law.

You agree to indemnify Skip Tracers for any third-party claim arising from your misuse of a report, as set forth in the Terms of Service.

9. Other applicable laws

In addition to the FCRA, GLBA, and DPPA, the following bodies of law may apply to your use of our services. This list is not exhaustive.

• Fair Debt Collection Practices Act ("FDCPA"), 15 U.S.C. §§ 1692 et seq. Debt collectors using our services to locate debtors must comply with the FDCPA's restrictions on third-party contact and disclosure.
• State consumer-protection and privacy statutes, including but not limited to the California Consumer Privacy Act / California Privacy Rights Act ("CCPA/CPRA"), the Illinois Biometric Information Privacy Act, the New York SHIELD Act, and other state-level frameworks that may apply based on the location of the customer, the subject, or the data.
• State licensing laws for private investigators and repossession agents. Many states require persons performing investigative or recovery work to be licensed. We do not provide investigative services to unlicensed persons in jurisdictions where licensing is required.
• Anti-stalking and anti-harassment statutes at the federal, state, and local level. Locating a person for the purpose of stalking, harassment, intimidation, or interference with their lawful activities is a crime, regardless of how the underlying information was obtained.

10. Reporting concerns

If you believe a Skip Tracers report has been or is about to be misused, by you, by your organization, or by a third party, report it immediately:

• Email: compliance@skip-tracers.com
• Phone: (818) 796-3826

We treat compliance reports as confidential to the extent permitted by law. Reports may be made anonymously.

If a subject of a Skip Tracers report believes that a report has been generated about them in violation of the FCRA, GLBA, DPPA, or other applicable law, they may also contact us at the email or phone number above. We will investigate every such report and respond within a reasonable time.

11. Contact

Skip Tracers
Compliance Office
Email: compliance@skip-tracers.com
Phone: (818) 796-3826

12. Changes to this notice

We may amend this notice from time to time. The "Last updated" date at the top of the page reflects the most recent revision. Material changes will be summarized in a banner on this page for thirty (30) days following the revision.

Your continued use of Skip Tracers after a revision constitutes acceptance of the revised notice.

This notice is provided for informational purposes and is not legal advice. Skip Tracers is not your attorney. If you have questions about your use of our services under the FCRA, GLBA, DPPA, or other applicable law, consult your own counsel before placing an order.