Consumer Credit Data & Dispute Management PolicyEffective Date: December 17, 2025
Policy Owner: Data Protection Officer (DPO) / Compliance Department1. Secure Storage & Encryption StandardsAll consumer credit information (including credit scores, reports, and payment histories) must be treated as "Highly Confidential."
- Database Encryption: All credit data must be encrypted at rest using AES-256 or higher. Databases must be "hardened," with all non-essential services disabled.
- Field-Level Encryption: Sensitive identifiers (e.g., Social Security Numbers, Full Account Numbers) must be encrypted at the field level, ensuring that even database administrators cannot view raw data without specific decryption keys.
- Transport Security: Any electronic transmission of credit data must occur over TLS 1.3 or higher.
- Access Control: Access is restricted via Zero Trust Architecture. All users must authenticate via hardware-based Multi-Factor Authentication (MFA).
2. Dispute Resolution PolicyWe are committed to maintaining the accuracy of consumer credit information. If a consumer disputes the completeness or accuracy of any information in our files, we will follow these steps:
- Submission of Dispute: Consumers may submit disputes via our Online Dispute Portal or by certified mail.
- Investigation Timeline: We will conduct a "Reasonable Investigation" and provide a response within 30 days of receiving the dispute (extended to 45 days if the consumer provides additional information during the 30-day period).
- Actionable Outcomes:
- Inaccurate Info: If the data is found to be inaccurate, we will update or delete the record immediately.
- Unverifiable Info: If the data cannot be verified, it must be removed from the consumer's file.
- Notification: We will provide the consumer with written results of the investigation and a copy of their updated report, if applicable.
3. Handling Disputed Consumer InquiriesWhen a consumer disputes an inquiry (the record of who accessed their credit file):
- Verification of Permissible Purpose: We will review internal logs to verify we had a "Permissible Purpose" under the FCRA to pull the credit data.
- Unauthorized Access: If the inquiry was not authorized or lacked a permissible purpose, we will contact the relevant Credit Reporting Agencies (CRAs) to have the inquiry suppressed or removed.
- Identity Theft: If the inquiry is disputed due to identity theft, we require a copy of a Standard Identity Theft Report to expedite the removal process.
4. Record Retention PolicyTo ensure compliance with federal and state laws while minimizing data risk, the following retention schedule is mandated for 2025:Record TypeRetention PeriodDisposal MethodConsumer Credit Reports3 years from date of pullCryptographic Erasure (Crypto-shredding)Dispute Records & Correspondence5 years from resolutionSecure Digital OverwriteAccess/Audit Logs7 yearsCompressed Archive with AES-256Inquiry Authorizations5 years from date of serviceSecure Digital Overwrite5. Secure DisposalOnce the retention period has expired, data must be destroyed in a manner that renders it unreadable and indecipherable. For encrypted databases, this includes the rotation and deletion of the encryption keys associated with that specific data block (Crypto-shredding).Compliance Resources
- For detailed guidance on federal requirements, refer to the FTC’s Credit Reporting Privacy Rules.
- Consumers may learn more about their rights via the Consumer Financial Protection Bureau (CFPB).