Rudy Ploder

President, Equifax Workforce Solutions

11432 Lackland Road

St Louis Mo 63146

Re: TALX Corporation (a provider of Equifax Verification Services), Consumer Reporting Agency Resale of The Work Number

Dear Mr. Ploder,

As representatives of Professional Background Screeners (“Screeners”), the undersigned wish to draw your attention to the many issues caused by recent abrupt changes to The Work Number (“TWN”) product configuration and associated billing practices.  These product changes, while not requiring development efforts or operational changes for Equifax Workforce Solutions (“Equifax”), have had a significant impact on our technology, billing systems and operations and will have a significant downstream impact on our employer end-user customers, many of whom are also your clients.  Equifax has had a history of unfairly forcing changes made to better service customers in other industries on the Screener with no regard for the impact to our businesses or our end-user customers.  We would appreciate an opportunity to partner with Equifax on rectifying these issues and to be properly considered in product changes going forward.

First and most importantly, end-user employer requests for verification of previous employment history are deliberate and specific.  Employers specifically request a recent history or history that aligns with work performed by a candidate that is “job related” or relevant.  When an employer seeks to verify the previous three employers or last five years of relevant work history, for example, returning a report that includes other employment that does not fall within the requested timeframe or that contains non-relevant work history, is of no use whatsoever but will still result in a major fee from TWN.  Further, returning work history in bulk only creates noise and confusion on the consumer report, making it more difficult for the candidate to understand the purpose, nature and use of the information on the report.  This raises concern related to temporary work or secondary/alternate sources of income that a prospective employer might unfairly consider when making an employment decision, resulting in unintended consequences, including costly litigation related to hiring decisions made by prospective employers. 

Next, Screeners are left to decide how to treat this information.  Without having the proper tools to know when to direct the request to TWN, such as “participating employers”, Screeners will be forced to send every request to TWN, knowing that TWN will return results that do not fulfill the request of the end-user and TWN will charge a fee to the Screener regardless of whether the results returned are of any use, whatsoever.  The Screener will then be forced to absorb this fee or in most cases pass it on to the end-user, without any corresponding results that are useful or related to the end-user’s request.  This is not only unfair to Screeners, it’s unfair to the end-users who will be forced to pay for information they do not find useful.

Plus, this change to TWN product was unfairly timed.  Screeners often plan their development roadmap items a year in advance and TWN made an unfair assumption that Screeners could simply remove the company code from their request and thereby consume all the information returned in the query.  In result, Screeners are investing significant dollars and development efforts to properly digest the data returned by TWN and are having to hire additional personnel to sift through the data while these changes are being made. 

It is unfair and unjust for Equifax to inappropriately group employment screening into other product types.  This issue is a perfect example of how mortgage companies or creditors have different use cases for work history and is justification to have the needs of the employment screening industry considered in product development and pricing decisions.  Screeners are outraged by these changes to TWN and are actively considering alternatives to querying TWN to meet the needs of end-user employers.  

We appreciate your attention to this matter and request an opportunity to meet with you as a group to discuss these issues and arrive at a product solution that is mutually agreeable. The ball is now in your court!


A Coalition of Screening Companies