We believe that you may be able to obtain an employee’s numerical credit score, provided that you obtain the employee’s authorization after clearly disclosing that you are pulling a numerical credit score (not an employee credit report). The FCRA expressly allows you to obtain a “consumer report” for any “employment purpose,” provided that you follow the disclosure and authorization requirements. 15 USC 1681b(b)(1). “Consumer report” is defined broadly to include “any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living.” 15 USC 1681a(d). And, “employment purposes” include “evaluating a consumer for employment, promotion, reassignment or retention as an employee.” 15 USC 1681a(h). Note that use of a numerical credit score would trigger several additional disclosures if you do take an adverse action based on the credit score (and we have omitted those disclosures below, on the assumption that you would not be pulling a numerical credit score).