Credit Header Data

Definition

Non-financial information appearing at the top of credit reports, including names, current and previous addresses, date of birth, Social Security number, employment information, and spouse's name. Credit header data is collected by credit reporting agencies but doesn't include financial information like credit scores, payment history, or account details. This data is particularly valuable for identity verification, fraud prevention, and marketing purposes. Privacy considerations arise because credit header data enables identification and tracking of individuals. While the Fair Credit Reporting Act regulates use of full credit reports, credit header data used alone receives less stringent regulation, though it's still subject to general privacy laws and reasonable use requirements. Data brokers often purchase and resell credit header data. Organizations using credit header data should ensure lawful basis, implement appropriate security, disclose use in privacy policies, and honor opt-out requests where applicable.

Applicable Laws & Regulations

  1. 1Fair Credit Reporting Act 15 U.S.C. §1681a(d)(2)(A) - Permissible purposes for credit report data
  2. 2FCRA 15 U.S.C. §1681a(o) - Limited application to header data used alone
  3. 3GDPR Article 6 - Lawful basis for credit header data processing

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