3
Gilberg held that when “a disclosure form does not consist solely of the FCRA disclosure, it does not satisfy the standalone document requirement.” Just like the disclosure forms provided by DMG, the disclosure forms at issue in
Gilberg contained state law disclosures which rendered them in violation of the FCRA standalone disclosure requirement.
In
Walker, the employer’s disclosure form included the following statement to the consumer:
“You may inspect [our background screening vendor’s] files about you (in person, by mail, or by phone) by providing identification [to our background screening vendor]. If you do, [they] will provide you help to understand the files, including communication with trained personnel and an explanation of any codes. Another person may accompany you by providing identification. If [our background screening vendor] obtains any information by interview, you have the right to obtain a complete and accurate disclosure of the scope and nature