Service Description

FCRA Compliance Statement
Last Updated: 01/08/2026

This Fair Credit Reporting Act (“FCRA”) Compliance Statement describes the respective obligations of TrueFingerprints LLC, operating the Personnelgraph platform (“Personnelgraph”), and its business customers (“Customer”) under the FCRA and applicable state laws.

This document is provided for informational purposes only and does not constitute legal advice.

1. Consumer Reporting Agency Status
Personnelgraph operates as a Consumer Reporting Agency (“CRA”) as defined under the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq.
Personnelgraph provides consumer reports for employment-related purposes based on information obtained from courts and other public record sources.

2. Permissible Purpose Requirement
Customer may only request and use consumer reports through the Platform for a permissible purpose under the FCRA.
Permissible purposes include, but are not limited to:
Employment decisions
Pre-employment screening
Promotion, retention, or reassignment decisions
Customer represents and warrants that:
Each request has a valid permissible purpose
Consumer reports are requested solely for lawful employment purposes

3. Authorization and Disclosure Obligations
Customer is solely responsible for:
Providing clear and conspicuous written disclosure to the consumer
Obtaining legally valid written authorization prior to requesting a report
Complying with all federal, state, and local disclosure requirements
While Personnelgraph provides tools to facilitate authorization collection, Customer remains responsible for legal sufficiency.

4. Accuracy and Reinvestigation
Personnelgraph maintains reasonable procedures designed to promote accuracy as required by the FCRA.
Consumers have the right to:
Request disclosure of their consumer report
Dispute the completeness or accuracy of information
Personnelgraph investigates disputes in accordance with the FCRA and applicable law.

5. Pre-Adverse and Adverse Action Responsibilities
Customer is solely responsible for complying with all pre-adverse and adverse action requirements under the FCRA, including but not limited to:
Pre-Adverse Action
Before taking adverse action, Customer must provide the consumer with:
A copy of the consumer report
A copy of the Summary of Rights Under the FCRA
Adverse Action
After taking adverse action, Customer must provide:
An adverse action notice
Contact information for Personnelgraph
Notice of the consumer’s right to dispute
Personnelgraph does not determine whether adverse action is appropriate.

6. Use and Interpretation of Reports
Customer acknowledges that:
Personnelgraph does not make employment decisions
Reports must be evaluated in context
Criminal records may not indicate current or relevant risk
Customer is responsible for ensuring decisions comply with:
The FCRA
Applicable state laws
EEOC guidance

7. Data Retention and Security
Personnelgraph implements reasonable administrative, technical, and physical safeguards designed to protect consumer data.
Customer is responsible for:
Secure handling of consumer reports
Limiting access to authorized personnel
Proper retention and disposal of reports

8. No Legal Advice
Personnelgraph does not provide legal advice regarding:
FCRA compliance
Employment decisions
Interpretation of reports
Customer should consult its own legal counsel regarding compliance obligations.

9. Relationship to Governing Documents
This FCRA Compliance Statement is governed by and subject to:
The Personnelgraph Terms of Service
Any applicable Order Form
Applicable privacy and data protection policies
In the event of a conflict, the Terms of Service control.

10. Contact Information
For questions regarding FCRA compliance, consumer rights, or disputes:
TrueFingerprints LLC
legal@personnelgraph.com