Can I Share a Background Report With Another Party?

The short answer is: generally, no — not without additional steps.

Consumer reports ordered through Verified First are subject to the permissible purpose requirements of the Fair Credit Reporting Act (FCRA). When you execute an MSA with Verified First, you certify that you have a legitimate, lawful reason — typically employment screening — to obtain and use those reports. That certification is specific to your organization and the candidates you are evaluating directly.
 

Why you can't simply share a report with a third party

Under the FCRA, each entity that receives a consumer report must independently have a permissible purpose for that report. Your permissible purpose — and your MSA with Verified First — does not extend to another organization, even one closely affiliated with yours. If a third party receives a consumer report without having their own agreement in place, that constitutes an unauthorized disclosure under federal law. This applies regardless of the relationship between the parties or how routine the arrangement may seem.

Common situations where this issue arises include:

• Staffing agencies sharing reports with the companies where candidates will be placed
• Parent companies sharing reports with subsidiaries or affiliates not covered under their own MSA
• HR service providers or PEOs sharing reports with their client-employers
• Any organization sharing reports with a vendor, partner, or decision-maker outside their own entity
   

What you can do instead

If a third party in your business process needs access to background screening results, there are compliant options:

• The third party executes their own MSA with Verified First. This is the cleanest resolution. Once they are credentialed, they can order and receive reports directly, or be properly authorized within a structured account arrangement.
• Adjudication results only. In some circumstances, you may communicate to the third party whether a candidate meets or does not meet your pre-established hiring criteria — without sharing the underlying report details, charges, dates, or any consumer PII. Your Account Manager can walk you through how this works.
• Candidate-initiated disclosure. A candidate may request their own consumer report from Verified First and share it directly with the third party. Because the candidate is initiating the disclosure of their own information, this bypasses the MSA requirement between the entities.
   

Important note: If you are considering any arrangement involving third-party access to background screening results, please contact your Account Manager before proceeding. They can help you identify the right path for your situation and ensure your account is structured to keep you compliant.

Verified First cannot provide legal advice. We strongly recommend consulting your own legal counsel regarding your obligations under the FCRA and any applicable state laws before making decisions about how consumer reports are used or shared within your organization.