The FCRA's requirement to report complete and up-to-date information is item-specific, which means any investigative report must include the current, complete, and up-to-date public record status of each individual item reported. The FTC has not indicated that a company has an obligation to continually update reports that it has already provided, but the report should be up to date at the time it is provided to a Client company, about a consumer.
As Biometrica carries real-time data, updated on a daily basis, our records match the most current available public records for an arrest. As this is real-time, a case would not have been adjudicated by a court at that point. We also update all law enforcement updates to the case as it moves through the system, when law enforcement updates the case concerned. In the case of DOC data, it is generally post conviction. Again, it is real-time, you get the information the same day it is updated in a law enforcement system by the jurisdiction concerned.
Algorithmically, the system first matches name and facial recognition against our 100% law enforcement-sourced multi-jurisdictional database, and then presents possible matches to a human — the company-authorized HR or compliance person — for a final determination. To elaborate, when the algorithms (machine intelligence) identify a possible match against name and facial biometric parameters, we then present an actual person (human intelligence) with all the arrested individual’s case data that the jurisdictional county makes available to us (which differs in the case of each county or county equivalent): That information could be name, photo, age, race, gender, height, eye color in one case, it could be name, photo, age, race, gender, in another, or age, gender, height, eye color, hair color in yet another. The final determination of a match between an employee and an arrested individual is not made by Biometrica directly or indirectly, through AI or humans; it is made by the employer or client company who know the employee best, and who are best placed to decide what to do with the information they have. Our obligation is to comply with the law, provide them with the data, and remind them of their obligations at every stage under the law, including the obligation to provide the employee with a copy of their consumer report.