November 8, 2015
by Carole Levitt JD MLS & Mark Rosch

For investigative research database searching, we have been recommending TLOxp to lawyers for many years because it was inexpensive and did not require a monthly or annual subscriber fee. While the search began at 0.25 and quickly went up to $1.00 and then $2.00, and the comprehensive report went from $5.00 to $10.00, a subscriber fee was never instituted.

On November 5, 2015, we received an email notifying us that all that is about to change effective January 1, 2016. TLOxp will be instituting a $25 monthly minimum spend requirement. You can avoid this spend requirement if the sum of your monthly usage is greater than $25, but if you fail to meet the $25 monthly minimum, you will be assessed $25.

Another new requirement is that you now must submit to a $60 site visit. In the past, this was optional; you only had to submit to a site visit if you wanted access to full Social Security Numbers and Dates of Birth.  It is unclear if the new site visit requirement will now entitle all users access to full Social Security Numbers and Date of Birth. TLOxp explains the reason for the mandatory site visit this way: “To help ensure the highest standards for data security, TransUnion is conducting a periodic compliance validation, including updating information we maintain about users and your organization. This includes conducting a site visit for the location from where you access the TLOxp account.” 

Unlike the new $25 minimum monthly spend, the site visit won’t actually cost you anything because, “Your invoice will be credited back $10 per month over a six-month period starting in January 2016, once the compliance validation is performed.” TLOxp has given customers very little notice to complete their site visit—it must be completed by December 15, 2015.  During the site visit, TLOxp will be looking at four main areas at your office:

1. Verification that the company information provided during the credentialing process is accurate. This covers questions such as whether your company is located at the address provided, and if it appears to be operating as the business type represented.
2. Security review around how the information is accessed. Is there a keyed locked office and a locking filing cabinet, an alarm or security present, the computers accessing systems limited to employees only, and screens situated to where only employees can view the screens, etc.
3. Information destruction. Shredders or a service that provides secure document destruction is common.
4. Secure storage of information obtained from the system. Locks on the file cabinets or file rooms where printed reports may be stored would be expected. Antivirus or security software should be installed on systems that will be accessing the data

If you are operating from a home-based location, prior to the site visit, TLOxp wants a documented response about the following issues, within five (5) calendar days of your $60 site visit payment:

1. Whether the office is in a dedicated space, separate from the living quarters. The office must be for the sole use of the business and not located in a multi-use room. Indications of multi-use include beds, recreational equipment such as pool tables, and exercise machines.
2. Whether the dedicated office space is separated by a keyed lockable door.
3. Whether secure storage for any printed reports or documents in the form of a lockable file cabinet exists.