Specifications
What Kōtsū enforces.
Each specification is a single FCRA obligation, turned into a control that acts at the moment the obligation applies — and produces a per-file record that it did. Thirty of them, across the screening workflow. Browse what each one ensures and where it intervenes.
Tier 1 — The Spine
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Adverse-Action Sequence
No adverse decision is finalized before the consumer has received the notice and the window the law requires.
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Permissible Purpose
A report is pulled only for a use the law actually permits — checked at the moment it is furnished, not assumed at signup.
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Disclosure & Authorization
An employment report is procured only after a standalone disclosure and the consumer’s written authorization.
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Identity Matching
An ambiguous match is sent to a person, not attached automatically — the mixed-file failure is routed away from.
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Dispute Reinvestigation
A dispute is re-investigated and answered within the statutory window — the clock cannot quietly lapse.
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Obsolescence
Stale, sealed, and expunged items are suppressed — the reporting windows are enforced as hard limits.
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Adjudication Matrix
No automatic disqualification on a criminal record without the individualized assessment the guidance calls for.
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Public-Record Reporting
Adverse public-record items are reported only with contemporaneous notice to the consumer, or under strict accuracy procedures.
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Tier 2 — Core Extensions
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Source Coverage
A report is not called complete until every agreed source has actually been queried.
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Database-to-Source Verification
A database hit is confirmed at the originating court before it is reported.
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Tenant Screening
Eviction-record accuracy and tenant adverse action, with the housing disparate-impact step.
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Investigative Reports
Investigative-report interviews happen only after the consumer disclosure.
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File Disclosure
A consumer’s file is released only after the requester’s identity is verified.
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Reinsertion
A previously deleted item cannot reappear without the five-day notice to the consumer.
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Continuous Monitoring
Post-hire monitoring re-confirms purpose on each hit and routes adverse ones into adverse action.
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End-User Credentialing
An account can pull reports only after permissible-purpose certification and FCRA attestation.
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Medical Information
Medical information stays redacted unless the narrow statutory conditions are met.
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Credit in Employment
Credit-report use in hiring is blocked where state or local law prohibits it.
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Tier 3 — Governance & Data Lifecycle
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Data Disposal
Consumer data is disposed of only by a verified secure-destruction method.
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Retention Schedule
Records past their retention window are purged — and not quietly re-retained.
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Access Logging
Every report access carries a logged permissible purpose and an authorized requester.
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Breach Response
A breach is assessed before notice goes out, and notice lands within the statutory window.
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End-User Re-Certification
Continued access depends on end-users periodically re-certifying their purpose.
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Verification Methods
Each credential is verified by the method and source the standard prescribes.
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MVR / Driving Records
Driving-record use is gated behind a DPPA permissible purpose.
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Drug-Screen Handling
Results pass through MRO review and stay out of the FCRA report path.
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International Screening
A global search runs only behind source-legality and cross-border consent.
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Furnisher Accuracy
A furnisher dispute is investigated before it can be resolved.
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Conflict Reconciliation
Conflicting source data is finalized only when reconciled; unresolved conflicts escalate.
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Fraud Alert / Security Freeze
A fraud alert or security freeze is honored before any report is furnished.
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