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Public records privacy statement

This Public Records Privacy Statement (“PR Privacy Statement”) provides information about our data collection and processing practices related to Thomson Reuters Westlaw Public Records (including, but not limited to, PeopleMap and Company Investigator) and CLEAR (collectively, the “Public Records Products”). This PR Privacy Statement is in addition to the Thomson Reuters Privacy Statement.

Thomson Reuters (including its affiliates and subsidiaries collectively “Thomson Reuters”) sources data from government agencies and third party private data providers (collectively, “Providers”). The nature of the data and the collection processes limit our ability to independently verify and/or validate the accuracy or completeness of any of the data and all data is subject to change at any time without notice. Our Public Records Products, including any data contained therein, are provided “as is” without any warranty of any kind. Thomson Reuters, its Providers and their directors, employees, contractors, and agents disclaim all warranties, expressed or implied, as to any matter whatsoever and shall not be responsible for any loss or damage that may directly or indirectly arise as the result of the use of the data contained in the Public Records Products.

Personal information that we may collect from individuals through their use of our products and services is never added to our Public Records Products or databases and is subject to, and only used in accordance with the Thomson Reuters Privacy Statement. We make our Public Records Products available only to authorized businesses and government organizations for their legitimate internal business uses (collectively, "Subscribers"). We comply with the requirements of applicable laws, such as the U.S. Gramm-Leach-Bliley Act (15 U.S.C. §§6801 et seq.) (“GLB”) and the U.S. Driver's Privacy Protection Act (18 U.S.C. §§2721 et seq.) (“DPPA”). If we reasonably believe that data has been misused, abused or compromised, we may block access without additional notice.  

THOMSON REUTERS IS NOT A CONSUMER REPORTING AGENCY, AND NONE OF THE INFORMATION PROVIDED THROUGH ANY OF ITS SERVICES CONSTITUTE A "CONSUMER REPORT" AS SUCH TERM IS DEFINED IN THE FEDERAL FAIR CREDIT REPORTING ACT (15 U.S.C.A. §§1681 ET SEQ) (“FCRA”).

BY ACCESSING A PUBLIC RECORDS PRODUCT, YOU AGREE THAT YOU WILL NOT UTILIZE THE DATA (I) AS A FACTOR IN ESTABLISHING AN INDIVIDUAL'S ELIGIBILITY FOR CREDIT OR INSURANCE, (II) IN CONNECTION WITH UNDERWRITING INDIVIDUAL INSURANCE, (III) IN EVALUATING AN INDIVIDUAL FOR EMPLOYMENT PURPOSES, (IV) IN CONNECTION WITH A DETERMINATION OF AN INDIVIDUAL'S ELIGIBILITY FOR A LICENSE OR OTHER BENEFIT GRANTED BY A GOVERNMENTAL AUTHORITY, (V) IN CONNECTION WITH ANY PERMISSIBLE PURPOSE (AS DEFINED BY THE FCRA), OR (VI) IN ANY OTHER MANNER THAT WOULD CAUSE SUCH USE OF THE SERVICE TO BE CONSTRUED AS A CONSUMER REPORT BY ANY AUTHORITY HAVING JURISDICTION OVER ANY OF THE PARTIES. MOREOVER, YOU AGREE NOT TO TAKE ANY ADVERSE ACTION, WHICH IS BASED IN WHOLE OR IN PART ON THE DATA, AGAINST ANY CONSUMER. THE TERMS "ADVERSE ACTION" AND "CONSUMER" SHALL HAVE THE SAME RESPECTIVE MEANING AS THOSE TERMS ARE DEFINED IN THE FCRA.

DATA MAY NOT BE USED FOR COMMERCIAL SOLICITATIONS, MARKETING, FUNDRAISING, OR OTHER SIMILAR ACTIVITIES.

 

FREQUENTLY ASKED QUESTIONS

DOES THOMSON REUTERS DISTRIBUTE DATA TO THE GENERAL PUBLIC?
Thomson Reuters does not distribute our Public Records Products or data to the general public. Our Public Records Products are only available to authorized Subscribers and their authorized end users.  Regulated data, including, but not limited to data that is governed by GLB and DPPA, is only made available to authorized Subscribers that have been vetted and have represented that they have a permissible use authorized by the applicable law.

WHO CAN ACCESS SOCIAL SECURITY NUMBERS (SSNs) THROUGH WESTLAW AND CLEAR?
Thomson Reuters takes steps to limit access to and the disclosure of SSNs, pursuant to applicable law. The majority of authorized Subscribers cannot access full SSNs. Only approved Subscribers within authorized government agencies (for example, law enforcement and certain government agencies), as well as certain private sector entities that have been qualified through a review process, may have access to full SSNs for lawful purposes.  Thomson Reuters prohibits the unlawful disclosure of SSNs and contractually requires Subscribers to keep this information confidential.

HOW DOES THOMSON REUTERS SECURE PUBLIC RECORDS AND PERSONAL INFORMATION?
At Thomson Reuters, protecting the data in our possession is at the core of our Information Security strategy. We have established policies and a governance structure to mitigate and respond to potential security risks. We align ourselves to multiple security and risk frameworks and assess the effectiveness of our security program on an ongoing basis. Thomson Reuters currently follows a 24x7x365 “follow the sun” Security Operations model with a global response footprint.

HOW DOES THOMSON REUTERS ACQUIRE THE PUBLIC RECORDS AND OTHER INFORMATION THAT IS AVAILABLE IN THE PUBLIC RECORDS PRODUCTS?
Thomson Reuters lawfully acquires the data from public and private Providers. In most cases, such acquisition occurs pursuant to a license agreement with our Providers. Some of our Providers require Thomson Reuters to pass additional terms through to you. These Providers change their terms occasionally without notice and new Providers are added from time to time. To see the current Supplier Additional Terms, click the following URL: http://www.thomsonreuters.com/thirdpartyterms.

HOW DOES THOMSON REUTERS COORDINATE DATA CORRECTION REQUESTS WITH ITS DATA PROVIDERS?
We take reasonable steps to accurately reproduce data we receive from our Providers; however, the nature of the data and the collection processes limit our ability to independently verify and/or validate the accuracy or completeness of any of the data and all data is subject to change at any time without notice. Sometimes the data we receive may contain errors. While some Providers will address requests for changes from members of the public, some will only acknowledge and consider requests for changes when they are submitted by resellers such as Thomson Reuters. Therefore, if you find an error on a Public Records Product concerning you, please send an email message to westlaw.privacypolicy@thomsonreuters.com. Based on the source of the data and the requirements of the Provider, we will notify you as to the documentation that you may need to submit in order to have the Provider consider making the requested change. Please be aware that inquiries are managed by the individual Provider—not Thomson Reuters—and each Provider has sole discretion as to what types of documentation it may request to address requests for modification and/or correction of data.

CAN I FIND OUT WHAT INFORMATION THOMSON REUTERS HAS ABOUT ME IN ITS PUBLIC RECORDS PRODUCTS?
Yes. You may request a copy of the information concerning you in our Public Records Products; however, please be advised that we are only able to provide a copy of the records referring unambiguously to you. To ensure your privacy, we will require you to verify your identity by submitting certain documentation to us. To request a copy of the information concerning you, complete the Personal Information Request Form and return it, along with a copy of your driver's license or government issued identification, to:

Thomson Reuters
Westlaw and CLEAR Public Records
ATTN: Personal Information Request
610 Opperman Drive
Eagan, MN 55123

Please note: the copy of your driver's license or government issued identification must be a clean, fully legible copy and will be used only to verify your identity. These copies will be destroyed when the process is complete. We reserve the right to charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).

If you have questions concerning the procedure to request information about yourself, please email westlaw.privacypolicy@thomsonreuters.com.

CAN I HAVE MY PERSONAL INFORMATION REMOVED?
You may request that your personal information be suppressed from our Public Records Products, however, all requests are subject to review and approval. Each request will be evaluated on the merits and in accordance with any applicable law. Requests are typically granted in relation to individuals who demonstrate he/she:

  • is a judge, public official or member of law enforcement; and/or
  • can provide evidence that the availability of his/her personal information on our Public Records Products exposes him/her to risk of physical harm; and/or
  • is a victim of identity theft.

We will require a written explanation substantiating the request and depending on the nature of the request, you may be required to provide:

  • copies of credentials (verifying his/her position in law enforcement or public office); and/or letters from supervisors (required when the requestor is a member of law enforcement or a public official); and/or
  • police reports or court orders (regarding potential physical harm); and/or
  • police reports or letters from credit reporting companies (regarding identity theft)

Though we use our best efforts to suppress information wherever possible, we are in fact limited in the databases from which we can remove information. Currently, we are unable to remove records from databases comprised of information made available by governmental agency, such as but not limited to court dockets,  real estate records, liens & judgments, lawsuits, death records, motor vehicle registration, or any information coming through one of our live gateways. Further, if you change your name, address or use slight variations of either, for example, after a request has been granted, you will likely reappear in our databases because they are refreshed and updated regularly.

To request that your information be suppressed in our Public Records Products complete the Public Records Personal Information Removal Request Form and return it with the supporting documentation to:

Thomson Reuters
Westlaw and CLEAR Public Records
ATTN: Personal Information Removal Request
610 Opperman Drive
Eagan, MN 55123

Suppressed Records will only be removed from the specific Public Records Product requested, and not from the database from which it originated.

Additional questions about who can request suppression of their personal information or what kind of documentation is required should be directed to westlaw.privacypolicy@thomsonreuters.com. Once a request to suppress personal information has either been granted or denied, that decision will be communicated to you in writing, subject to applicable law.

LICENSE PLATE RECOGNITION (“LPR”) DATA – GATEWAY USAGE AND PRIVACY POLICY

Use of LPR Data. Access to LPR data via the gateway in CLEAR is limited to authorized Subscribers that have a legitimate law enforcement or investigative purpose and a permissible use under the U.S. Drivers Privacy Protection Act (18 U.S.C. §2721 et seq.) (“DPPA”). 

Users and Training. Employees and subcontractors of Thomson Reuters who receive compliance training regarding the appropriate use of and access to Public Records Products (including without limitation LPR data contained therein) may be authorized to access and use the LPR data to demonstrate the system to actual and potential subscribers, to provide customer support, and to maintain the LPR data and CLEAR. Subscribers are authorized to access the LPR data in accordance with this policy. Subscribers are required to maintain the confidentiality of the LPR data and to train all end users on its confidentiality and permissible use obligations.

Monitoring and Compliance. Use and access to LPR data is monitored in accordance with Thomson Reuters standard procedures to ensure the security of the LPR data and compliance with applicable laws, rules and regulations. Furthermore, we maintain usage logs in accordance with DPPA requirements and these are audited as needed.

Sales, Sharing or Transfer of LPR Data. We authorize access to the LPR data in accordance with this policy. All subscribers are required to have entered into a definitive agreement with us prior to accessing the LPR data.

Custodian/Owner of the LPR System; Accuracy; Data Retention. Vigilant Solutions, Inc. is the custodian and owner of the LPR Data that is accessible via CLEAR. Please see Vigilant’s Usage and Privacy Policy (https://www.vigilantsolutions.com/lpr-usage-and-privacy-policy/) for information on data accuracy and retention.

Subscribers to LPR Data. If you are a subscriber accessing the LPR data within CLEAR, you agree that your use does and will always comply with all applicable laws, rules and regulations, including without limitation California Civil Code §§1798.90.5-1798.90.55 and other similar state statutes.

WORLD-CHECK DATA

Data Use. This information was obtained from the External Source(s) listed in the specific record and should be verified with that entity prior to any decisions being made. Neither Thomson Reuters nor World-Check have verified or validated the accuracy or completeness of this information and any negative allegations or correlation should be assumed denied by the subject. If you are using this data to determine whether to enter into or maintain a business relationship with an individual, you must direct or provide the individual you are searching with a copy of the World-Check Privacy Statement located at https://risk.thomsonreuters.com/en/terms-of-business/world-check-privacy-statement.html

Data Inquiries. If you believe the information is incorrect or inaccurate please click here to contact World-Check. If you believe this information has been incorrectly correlated in the search results please contact Thomson Reuters at westlaw.privacypolicy@thomsonreuters.com.

NOTICE
This PR Privacy Statement may be revised without notice. If our information practices change in a material way, we will post the changes here. This Privacy Statement was last updated on January 15, 2019.