Imperative is a consumer reporting agency as defined by the federal Fair Credit Reporting Act and the analogous laws of several states. This means that Imperative collects and disseminates information about individuals for use by our clients in making decisions related to business transactions involving the consumer. These individuals are called consumers and these reports are called consumer reports.
Common examples of consumer reports include employment background checks and tenant screening.
Prior to requesting such reports from Imperative, our clients have disclosed to the consumers that such reports will be procured and obtained their written authorization to procure such reports.
Imperative will not provide a consumer report in any circumstance without certification or demonstration from our client that the written consent of the consumer has been obtained and that the applicable state and federal laws’ requirements have been met by the client.
Consumer information provided to Imperative, whether by a client or a consumer, will not be shared with any parties other than:
- The client whose request initiated the creation of the consumer report,
- Other firms engaged to assist Imperative in the preparation of the report, but only to the extent necessary to prepare the report,
- Information providers from whom information is requested, but only to the extent necessary to obtain such information,
- The consumer, upon receipt of a written request for access to the information held by Imperative about them.
Imperative does not include information collected in the preparation of previous consumer reports in subsequent consumer reports without first verifying that the information is accurate and up-to-date. Imperative does not maintain for resale any database of consumer information.
Imperative does not send any consumer information outside of the United States for processing or storage, except in the limited situation where such information is required to accurately identify relevant information about the consumer in the records of foreign schools, employers, or government entities.
Imperative follows a strict practice of verifying that any public record information about a consumer is verified with the government entity possessing such public record information prior to including the information in a consumer report.
A consumer wishing to dispute the accuracy of any information contained in a consumer report provided by Imperative should call Imperative at toll free (877) 473-2287.
Other Business-Related Investigations
Some reports prepared about individuals on behalf of our clients are not consumer reports as defined by federal or state laws and in such cases, Imperative is not acting as a consumer reporting agency and such reports will include no information that was collected in the preparation of a consumer report.
However, in such cases, Imperative will comply with the Gramm-Leach-Bliley Act, the Driver’s Privacy Protection Act, the Texas Private Security Act, and any other applicable state or federal laws.
Though such reports are not consumer reports, Imperative will not provide a person’s personally identifiable information (name, address, social security number, date of birth) to another person or company without first determining that the information is being used for a legitimate legal purpose or first obtaining the consent of the individual to release such information.
Credit Card Information
All web-based credit card payment transactions through www.imperativeinfo.com or reports.imperativeinfo.com are secured. Imperative does not retain any credit card information after completion of online payment transactions, including credit card numbers, billing address, or names or other information regarding payors.
Imperative uses technology to manage and track the use of the websites at https://www.imperativeinfo.com and http://www.pfcinformation.com (together, “the websites). At a minimum, the IP address, unique device identifiers, browser type, browser language and other transactional information (e.g., activity on each page visited) of each visit will be recorded using third-party tools. For marketing purposes, this information may be combined with personal information already in our possession.
Completing and submitting forms on the websites will result in additional personal information such as name, email address, phone number, employer, and product interest being collected by Imperative for marketing purposes.
Other than using third-party services such as Google Analytics and Facebook to collect and analyze this information, Imperative does not share this information with any other third parties except for the limited purpose of processing it for our own marketing purposes.
Privacy Shield Framework
Imperative Information Group, Inc. is a consumer reporting agency subject to the jurisdiction of the Federal Trade Commission.
Personal information on an EU or Swiss citizen collected by Imperative and subject to the Privacy Shield Framework will vary according to our client’s legitimate business purpose and may include, where legally permissible, current and previously-used names, email address, IP address, date of birth, social security number or national identification number, driver’s license number, current and previous addresses, criminal history information, civil litigation information, government or regulatory sanction information, employment history information, education information, US credit history information, and other information relevant to the individual’s credentials, reputation, past actions, and mode of living.
In many cases, it will be necessary for Imperative to provide the personally identifying information of an EU or Swiss citizen to third parties who provide information to Imperative. This is often necessary to identify relevant information and ensure that the information provided to Imperative belongs to the individual on whom a background check is being prepared. Imperative has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Imperative will remain liable under the Privacy Shield Framework if its agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless Imperative proves that it is not responsible for the event giving rise to the damage.
Imperative will only provide information on EU or Swiss citizens to customers who have received the individual’s signed consent and provided that signed consent to us. If an individual does not wish for this information to be shared with our customer, the individual should not provide the signed consent to the customer.
Imperative will not disclose the personal information of an EU or Swiss citizen to a third party other than the customer to whom the individual provided their written consent or, to the most limited extent necessary, to research and information sources who will verify the information provided by the individual to our customer.
Imperative will not use personal information on EU or Swiss citizens for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals.
An individual may opt out of any sharing of their information with any third party by either (1) refusing to provide our customer with a signed consent or (2) contacting Imperative at +1 (817) 921-5286 and asking to speak to Imperative’s privacy officer.
EU or Swiss citizens whose personal data is processed or maintained by Imperative have a right under Privacy Shield to review, correct, or, except where Imperative has a legal obligation to maintain such data, delete their personal data.
To ensure and defend our compliance with applicable US federal and state laws, Imperative maintains personal data used in the compilation of consumer reports for a minimum of six years. If an individual does not wish for Imperative to collect or maintain their personal data, they should not consent to the procurement of a consumer report.
Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel created by the U.S. Department of Commerce and the European Commission.
In some circumstances, Imperative may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Imperative commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable) and comply with the advice given by the panel and/or Commissioner, as applicable, with regard to data transferred from the EU and/or Switzerland, as applicable.
Any questions or concerns regarding privacy should be directed to:
Imperative Information Group, Inc.
1550 West Berry Street
Fort Worth, Texas 76110
Imperative will respond to any complaints made under the Privacy Shield Framework within 45 days of receipt.