Terms of use
Consumer reporting agency
By using Gram you agree to these terms. They are short because the service is narrow: it evaluates resume claims for material inflation, nothing more. Because that evaluation looks up public information about a named person and reports what it finds to you, the law treats it as a consumer report, and the section on the FCRA below is the part you must read.
What the service does
Gram analyzes the documents a reviewer uploads and restates claims at the information value the available evidence supports. To do that it searches public sources — scholarly indexes, code-hosting sites, company pages, the open web — for the applicant and the things they claim, and reports what it found and did not find. It does not certify any claim as true, and it does not make hiring or admissions decisions — the reviewer does.
The report on each applicant is assembled from public information about that person and furnished to you for a decision about them. That makes Gram a consumer reporting agency and the report a consumer report under the Fair Credit Reporting Act (15 U.S.C. §1681 and following, the “FCRA”), whether the decision is about employment or admission.
Consumer reports and the FCRA
Gram is the consumer reporting agency; you are the user of the report.
The FCRA places duties on both. Gram's duties (reasonable procedures for accuracy, giving applicants access to their file, reinvestigating disputes, keeping the records that prove all of it) are described on the privacy page and the applicant rights page. Yours are below.
You certify your purpose.
Before Gram will run a check, an administrator of your workspace must certify in Settings, and you re-certify with every import, that: (a) you will use each report only for the purpose you selected, employment or admissions, and for no other purpose; (b) for employment, you have complied with or will comply with the disclosure and authorization requirements of §604(b) of the FCRA for every applicant, either by asking Gram to send them on your behalf or by attesting that you did so yourself; (c) you will not use any report in violation of any federal or state equal employment opportunity law or regulation; and (d) you have read the state-law acknowledgements that apply to where you and your applicants are located. Gram relies on that certification and will not furnish reports to a workspace that has not made it.
Disclosure and authorization (employment).
The FCRA requires that, before you procure a report for employment purposes, the applicant receives a clear and conspicuous written disclosure, in a document that consists solely of the disclosure, that a consumer report may be obtained, and gives written authorization. When you choose “Email each applicant” at import, Gram sends that disclosure and collects that authorization on your behalf and holds the check until the applicant answers. When you choose “We already obtained authorization”, you attest that you did, and you are responsible for that attestation being true. Either way you, not Gram, are the person the FCRA holds to §604(b).
Before and after an adverse decision.
If you intend to take any adverse action based in whole or in part on a report — declining to hire, promote or retain; withdrawing an offer; declining an application — the FCRA requires that the applicant first receive a copy of the report and a summary of their rights, and that after the decision they receive notice of it, the name and contact details of Gram, a statement that Gram did not make the decision and cannot explain it, and notice of their right to a free copy of the report and to dispute it. Gram sends those notices on your behalf when you mark a document “Not proceeding”, and waits a reasonable period between the two. You agree not to take adverse action based on a report without those notices having been sent, and you remain responsible for their timing and content under the FCRA and any stricter state or local rule.
[COUNSEL: confirm that a CRA may send §604(b)(3) pre-adverse and §615(a) adverse notices as the user's agent, that this section makes the customer's instruction to do so sufficiently explicit, and how the certification in Settings must read to satisfy §604(b)(1) and §607(a).]
Prohibited uses.
You may not: use a report for any purpose other than the one you certified; use it in connection with credit, insurance, tenancy, or any decision about a person who is not an applicant to you; procure a report on a person who has not received the required disclosure, where one is required; share, resell, or publish a report or any part of it beyond the people in your organization who need it for the certified decision; use a report to discriminate on any basis protected by law; or use the service to build a profile of a person for its own sake. A workspace found doing any of these will be closed and the reports it holds deleted.
Disputes and reinvestigation.
An applicant may dispute the accuracy or completeness of anything in a report, directly with Gram. Gram reinvestigates, tells you a dispute is open, marks the report as disputed while it is, and tells you the outcome. You agree not to rely on a disputed item while the reinvestigation is open, and to give Gram any context you have that bears on it.
State laws.
Many states and cities add duties on top of the FCRA. California (the Investigative Consumer Reporting Agencies Act, including the applicant's right to a copy of the report), New York (Correction Law Article 23-A and the New York City Fair Chance Act's timing rules), and the “ban the box” laws of many jurisdictions are the ones that most often apply to a check like this one. Gram attaches the state notices it knows about when your workspace acknowledges them, but you are responsible for knowing which laws apply to you and your applicants and for complying with them.
[COUNSEL: confirm the list of state and local regimes that apply to an open-web verification report used for employment and for admissions, the CA ICRAA contents and copy-request mechanics, and NYC Fair Chance timing, before this section is relied on.]
Acceptable use
Use the service only on documents you are entitled to review, and only for evaluating them. Do not use it to harass or profile applicants, to scrape or resell its output, or to probe or disrupt the service itself.
Advisory output, no warranty
The analysis is automated and can be wrong: a claim may be tiered too harshly, too generously, or restated inaccurately. Reports are advisory input to a human decision, not a determination, and the service is provided as-is, without warranty of any kind. Nothing in this section limits the duties either of us owes an applicant under the FCRA.
Limitation of liability
To the maximum extent permitted by law, Gram is not liable for decisions made on the basis of its reports or for any indirect or consequential damages arising from use of the service. You are liable for any claim that arises from your use of a report in breach of the certification you gave or of the section on the FCRA above.
Contact
Questions about these terms: nathan@nolarping.com. Applicants with a question or dispute about a report: disputes@nolarping.com.