Disclosure and authorization do different jobs
One document tells the person a report may be obtained. The other is written permission to obtain it.
Module 1 of 7 · 7 min read
Section 604(b) of the FCRA, which the FTC's Leathers opinion quotes, requires a clear and conspicuous disclosure that a consumer report may be obtained for employment purposes, in a document that consists solely of the disclosure, and written authorization from the consumer. Those are two duties. They can share a packet in the candidate flow, but they are not the same sentence in an application. This lesson is educational and is not legal advice.
PreHireBadge Academy courses are free and educational. Completing a course or earning a certificate is not legal advice, not a professional license, and not a legal credential. Laws change. Read the cited sources and ask a qualified attorney about your own hiring decision.