Get the weekly research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean. No account.
The notice states that Uber collects background check reports including criminal and driving records from third-party providers to assess and maintain driver eligibility, with ongoing periodic updates to this data.
This analysis describes what Uber's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The collection and use of background check data for platform eligibility decisions implicates the Fair Credit Reporting Act (FCRA) requirements for adverse action notices and permissible purpose, and the periodic update mechanism means drivers may be subject to ongoing screening throughout their engagement with the platform.
Interpretive note: The frequency of periodic background check updates and the specific adverse action procedures applied to ongoing checks versus initial onboarding checks are not fully specified in the notice text available.
This provision establishes that criminal and driving record background check data is collected at onboarding and updated periodically, and is used to make eligibility determinations that may affect drivers' ability to remain on the platform; FCRA adverse action notice rights apply to US drivers when this data results in a negative eligibility determination.
How other platforms handle this
We may also collect and use personal information with your consent...You can revoke your consent at any time (mostly through our services directly), though note that you might not be able to use any service or feature...
The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Data we hold about you in a machine-readable format
Monitoring
Uber has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 20 platforms.
"Uber collects background check and identity verification information about drivers and delivery people, including criminal records, driving records, and other information obtained through third-party background check providers. This information is used to verify eligibility to use the platform and may be updated periodically.Excerpt from Uber's Privacy Notice (Drivers and Delivery People)
1) REGULATORY LANDSCAPE: Background check data use for employment or independent contractor eligibility implicates the Fair Credit Reporting Act (FCRA), which requires permissible purpose, pre-adverse action disclosure, adverse action notice, and dispute rights when consumer report data is used to deny or limit engagement. The FTC and CFPB share FCRA enforcement authority. State background check laws in California (ICRAA), New York, and other states impose additional requirements including ban-the-box provisions for certain contexts. 2) GOVERNANCE EXPOSURE: Medium. The periodic update mechanism for background checks means FCRA obligations recur each time updated background check data is used to make an adverse eligibility determination. Compliance with pre-adverse action and adverse action notice requirements for each such determination is operationally significant given the volume of driver relationships. 3) JURISDICTION FLAGS: All US states (FCRA applies nationally; state background check laws impose additional requirements in California, New York, Illinois, and others), EU/EEA (criminal record data is special category data under GDPR Article 10, requiring specific legal basis and Member State authorization), UK (UK GDPR and DBS check regulations). 4) CONTRACT AND VENDOR IMPLICATIONS: Third-party background check providers are consumer reporting agencies under FCRA; vendor agreements must include FCRA-compliant certifications of permissible purpose and restrictions on data use. Periodic screening vendors should be assessed for FCRA compliance and for accuracy of records. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that FCRA-compliant adverse action notice workflows are in place for both initial and periodic background check outcomes that affect driver eligibility. State-specific background check law requirements should be mapped against Uber's driver population distribution. EU criminal record data processing legal basis (typically Article 10 GDPR read with national law) should be documented for each Member State where drivers are screened.
Regulatory citations, enforcement risk, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
The collection and use of background check data for platform eligibility decisions implicates the Fair Credit Reporting Act (FCRA) requirements for adverse action notices and permissible purpose, and the periodic update mechanism means drivers may be subject to ongoing screening throughout their engagement with the platform.
This provision establishes that criminal and driving record background check data is collected at onboarding and updated periodically, and is used to make eligibility determinations that may affect drivers' ability to remain on the platform; FCRA adverse action notice rights apply to US drivers when this data results in a negative eligibility determination.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Uber.