Fellow colleagues. 

Yesterday, I reported that former Legislative Chair Jimmie Mesis was going to have a telephone conference call with TLO principals. As promised, Jimmie's report of this contact is below. Thank you, Jimmie. It is an important message. 

 

Please do not forget the other valued data provides who have supported and fought for private investigators for years. I want to specifically recognize IRB Search, Tracers, Skipsmasher, Palltech, Locate Plus and Skipmax for their valued contribution to the investigative profession. It is also important to mention Merlin Information Services, a valued contributor for many years before becoming part of TLO and closing their doors. In my opinion, it is important to subscribe to at least three providers and not put all of your eggs in one basket, so to speak. All of the data providers gather and aggregate information a little differently and you may find varied information with each one. 

 

Francie Koehler

 

Colleagues,

 

There have been a myriad of emails and listserve postings in the last two days about TLO and the changes they announced this week. Many of you have voiced your opinions and conjecture as to why this was happening.  As a professional investigator, I have always found it best to not assume anything and get the facts right from the source. This morning, I was granted an exclusive one hour interview with TLO's CEO, their Senior Vice President of Sales and Business Development, and their Director of Security and Compliance.

 

This week, TLO released changes within its TLOxp product.  These changes deal with data permissions and were not specific to PIs and have effected a variety of industries.  Some of these changes resulted in the truncation and/or full masking of certain sensitive data such as SSN and DOB.  Obviously, many PIs, Process Servers, Repo Agents, and Collection agencies have voiced their concern. TLO understands that restrictions on data can have an impact on its clients, but these changes were necessary to comply with restrictions placed upon TLO by credit bureaus and specific data providers. 

 

There are many rumors and assumptions currently being circulated within the PI profession.  However, here are the facts as presented through my interview:

• These changes were not a result of TLO management making its own internal decisions regarding the need of such data by certain industries or individual accounts.
• Changes in data permissions are in no way indicative of TLO's health as a company overall - TLO continues to grow at a remarkable pace, now currently serving thousands of entities and tens of thousands of individual users.
• TLO compiles and links a large number of datasets, providing a comprehensive investigative tool centered around people, businesses, assets, and the identification of common links between them.  While the common perception is that all sensitive data falls under standard regulatory rules (i.e. GLB and DPPA), such regulations are only part of the overall compliance picture that a large data fusion company like TLO must adhere to.  Certain data sources, credit bureaus as an example, have further contractual restrictions on the data in terms of how, and to whom, such data may be disseminated.  TLO continues to provide full, unrestricted access to all data that they are permitted.

For the Private Investigator profession in particular, the following changes were released:

• NON HOME BASED PI ACCOUNTS

o   A certain portion of SSN and DOB data that is only received from single-type sources is now truncated.  This truncated portion does not represent the majority of such data available through TLOxp - much of this data will remain fully available because it is obtained and verified through multiple additional sources

o   Accounts will be required to undergo a physical site inspection in order to continue to receive Utility data and a portion of additional location data that is specific to a single credit bureau source requiring such inspection.  This optional site visit is not needed to maintain a TLOxp account, only to receive access to the aforementioned data.

• HOME BASED PI ACCOUNTS

o   TLO is only permitted to provide credit bureau specific data to accounts that are located in an owned residence and that have passed a physical site inspection.  Entities falling outside of this will retain access to non-bureau sourced information.  Such accounts also lose access to Vehicle and Utility data. Again, these are restrictions placed upon TLO by specific data sources.

o   Upon a successful site visit, home based accounts will receive truncated SSN and DOB (including certain bureau data) but will not have access to Vehicle data.

 

It should be noted here that TLO has been paying the site inspection fee for thousands of its existing accounts and has only been charging site inspection fees for new accounts.

 

Bottom line, TLO is simply making sure that they and all of their customers are complying with the terms and conditions of usage that were established by each of the unique data suppliers. While the three credit bureaus may have some of the most up to date information, they also have the most restrictions because they also have the most exposure, and risk.

 

I have been assured that the Private Investigator profession remains an important part of TLO's client base and TLO remains committed to serving our profession.  As such, TLO has instituted an aggressive plan to address the ongoing needs of PI's.  Within the next three weeks, TLO expects to complete a major "re-programming" of existing data and a major infusion of data that will greatly lessen the impact of the recent changes. I was also able to ascertain that TLO has no plans of increasing the $1 they charge for reports as well as no minimums or monthly fees.

 

There is no doubt in my mind that TLO will be able to continue to provide valuable data to private investigators, but going through a companywide compliance review may have an effect on many investigators. I suggest that if you have any questions, please contact your TLO representative directly and do not reply to this list or to me personally.

 

Keeping the profession informed,

 

Editor-in-Chief

4400 Route 9, suite 1000
Freehold, NJ 07728
T - (732)308-3800   F - (732) 303-3314   www.PImagazine.com

 

(Permission granted for re-posting this message to any PI related list/newsletter)

 

Want to add your voice to the efforts to address restrictive legislation and protect your profession? 

Go to www,nciss,org for membership information. Check out other links on the web site as well.