Consumer complaint received 2024-09-18
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account status incorrect
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC. (GA)

Dear Sir/Madam, I am writing to you in regard to the information listed on my credit report associated with my Social Security number . It has come to my attention that there are aliases and other information reported by your agency that are not directly from a VERIFIED RECORD. I am deeply concerned about the privacy and accuracy of this information, as my Social Security number is a private identifier and should only be used by entities with whom I AUTHORIZED AND have direct business dealings. 
Under the Fair Debt Collections Practices Act ( FDCPA ) and the Fair Credit Reporting Act ( FCRA ), information reported by credit reporting agencies must be accurate, verified, and validated. It is my understanding that information associated with my Social Security number should only be reported if it is directly from a creditor and meets these standards. Any reporting of aliases or other information obtained from public data gathering aggregators violates my right to privacy and fails to meet the legal requirements outlined by the FDCPA and FCRA, AS SUCH INFORMATION IS NEITHER ACCURATE, VERIFIED, OR VALID AS REQUIRED BY LAW. MY SOCIAL SECURITY NUMBER HAS NEVER BEEN ASSOCIATED WITH THE PUBLIC RECORDS, AND SUCH RECORD GATHERING MUST BE DEEMED INACCURATE IF THERE IS A CLAIM THAT IT IS. 
Accuracy of information ( 15 U. S. C. 1681e ( b ) : This section requires that consumer reporting agencies follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates.

Dispute Resolution ( 15 U.S.C. 1681i ) : This section outlines the procedures that must be followed when a consumer disputes the accuracy of information in their credit report. It mandates that consumer reporting agencies must investigate disputes, usually within 30 days, and either verify, correct, or delete the disputed information.

Furnisher Responsibilities ( 15 U.S.C. 1681s-2 ) : This section details the responsibilities of entities that furnish information to consumer reporting agencies. It requires furnishers to provide accurate information, investigate disputes received from consumer reporting agencies, and correct or delete inaccurate or unverified information. You list aliases, who provided this information to you? You list previous addresses, who provided this information to you? 
Fair Debt Collection Practices Act ( FDCPA ) Acquisition of Location Information ( 15 U.S.C. 1692b ) : While not directly about information accuracy, this section Dear Sir/Madam, I am writing to you in regard to the information listed on my credit report associated with my Social Security number . It has come to my attention that there are aliases and other information reported by your agency that are not directly from a VERIFIED RECORD. I am deeply concerned about the privacy and accuracy of this information, as my Social Security number is a private identifier and should only be used by entities with whom I AUTHORIZED AND have direct business dealings. 
Under the Fair Debt Collections Practices Act ( FDCPA ) and the Fair Credit Reporting Act ( FCRA ), information reported by credit reporting agencies must be accurate, verified, and validated. It is my understanding that information associated with my Social Security number should only be reported if it is directly from a creditor and meets these standards. Any reporting of aliases or other information obtained from public data gathering aggregators violates my right to privacy and fails to meet the legal requirements outlined by the FDCPA and FCRA, AS SUCH INFORMATION IS NEITHER ACCURATE, VERIFIED, OR VALID AS REQUIRED BY LAW. MY SOCIAL SECURITY NUMBER HAS NEVER BEEN ASSOCIATED WITH THE PUBLIC RECORDS, AND SUCH RECORD GATHERING MUST BE DEEMED INACCURATE IF THERE IS A CLAIM THAT IT IS. 
Accuracy of information ( 15 U. S. C. 1681e ( b ) : This section requires that consumer reporting agencies follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates.

requires any debt collector communicating with any person other than the consumer to acquire location information about the consumer without stating that the consumer owes any debt. ] SUPPLEMENTAL INFORMATION : Various laws have been enacted to protect the privacy of individuals SSNs, restricting their use and disclosure. Here are five relevant laws and five case citations that reflect the legal landscape around the protection of Social Security numbers.

Laws Protecting Social Security Numbers Privacy Act of 1974 ( 5 U.S.C. 552a ) : This Act restricts how the federal government can disclose personal information, such as Social Security numbers. It mandates that government agencies must have relevant and necessary reason to collect an individuals SSN and must also inform individuals how their SSN will be used. 

Social Security Number Protection Act of 2010 : This Act specifically prohibits the printing of an individuals Social Security number on checks issued for payment by the federal government, as well as on any card required for accessing government services, in order to reduce the risk of SSN theft.

Family Educational Rights and Privacy Act ( FERPA ) ( 20 U.S.C. 1232g ) : FERPA protects the privacy of student education records. It applies to all schools that receive funds under an applicable program of the U.S. Department of Education. Schools must have written permission from the parent or eligible student to release any information from a students education record, which includes the Social Security number, except under certain legally specified circumstances.

Fair and Accurate Credit Transactions Act ( FACTA ) of 2003 : Amends the Fair Credit Reporting Act to enhance the accuracy of reports and includes provisions to help reduce identity theft, such as the truncation of credit card and Social Security numbers on printed receipts. 

Identity Theft and Assumption Deterrence Act of 1998 ( 18 U.S.C. 1028 ) : While not solely focused on SSNs, this Act makes it a federal crime to knowingly use another persons identification with fraudulent intent, which includes the unauthorized use of someones Social Security number. 

Case Citations Regarding Social Security Number Privacy In re XXXX XXXX XXXX, Customer Data Security Breach Litigation, 888 F. 3d 1020 ( 9th Cir. 2018 ) : Although not exclusively about SSNs, this case dealt with the broader issue of personal information security, including SSNs, in the context of a data breach. 

XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) : This case addressed damages related to the unauthorized disclosure of an individuals Social Security number by the government underscoring the privacy interests associated with SSNs. 

XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX ( XXXX Cir. XXXX ) : This case involved the issue of an employers responsibility to protect employees Social Security numbers and the legal ramifications of failing to do so. 
XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX XXXX ) : In this case, the court discussed the privacy implications of collecting and potentially disclosing students Social Security XXXX without proper safeguards. 
XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) : This New Hampshire Supreme Court case emphasized the duty of information brokers to exercise care in disclosing personal information such as Social Security numbers to third parties, highlighting the potential for harm from disclosures. 
These laws and cases highlight the legal protections afforded to Social Security numbers and the serious considerations given to their privacy and security in various contexts, including federal records, educational settings, and identity theft prevention. 
Communication in Connection with Debt Collection ( 15 U.S.C. 1692c ) : This section prohibits deceptive collection practices, indirectly requiring that any information communicated not be misleading or inaccurate. 
Validation of Debts ( 15 U.S.C. 1692g ) : This pivotal section requires debt collectors to provide consumers with a written notice containing the amount of the debt, the name of the creditor, and a statement that unless the consumer disputes the validity of the debt within 30 days, the debt will be assumed to be valid by the debt collector. 
Consumer Credit Protection Act ( CCPA ) The CCPA is a broader act that encompasses several statutes, including the Truth in Lending Act ( TILA ), the FCRA, the Equal Credit Opportunity Act ( ECOA ), and the FDCPA among others. Specific requirements for verified, validated, and accurate information reporting are more directly addressed in the acts mentioned above. However, the CCPAs establishment of these acts under its umbrella signifies the legislative framework for consumer credit protection, including accurate and fair credit reporting and debt collection practices. 

Consequences for Non-Compliance Failure to comply with these requirements can result in several consequences for creditors, debt collectors, and consumer reporting agencies, including : Civil Liability ( e.g., 15 U.S.C. 1681n, 1681o for FCRA ) : As a consumer I can bring civil action against violators for actual damages, statutory damages, and in cases of willful non-compliance, punitive damages, I prefer to bring the claim against their insurance bonds. 

Enforcement Actions : Agencies such as the Federal Trade Commission ( FTC ) and the Consumer Financial Protection Bureau ( CFPB ), along with the Small Claims Court having jurisdiction, can enforce these laws, potentially resulting in fines, penalties, and injunction/directives to correct practices. 

Reputational Damage : Non-compliance can also lead to reputational damage, i.e., : libel and slander elements of defamation of character, and civil action affecting the business relationships and consumer trust of violating entity. 

Therefore, I formally challenge the accuracy and validity of any information on my credit report that does not meet these standards. I request that you promptly investigate and remove any such information from my credit report. Failure to do so will result in further action, including pursuing legal remedies available to me under the law. This presentment contains specific reference to the disputed information in question format and otherwise! 

Please this matter. 

Thank you for your prompt attention to this issue. 

Sincerely, XXXX XXXX provide me with written confirmation once the investigation is complete and any accuracies have been corrected. You may contact me at the address provided above if you require any additional information or clarification regarding