Investigative Report Data: CSAM Guide
This guide is for CSAM and support conversations with law firms that use investigative report data from providers such as TLO, TransUnion, or LexisNexis.
Use it when a customer asks questions like:
- "Can we load these numbers into Kayse?"
- "Can we call family members from a TLO report?"
- "How should we handle deceased clients and settlements?"
- "Can we use Kayse to help find a missing client?"
The Short Version
The safest summary is:
- Kayse is for the original client who signed the retainer, or for a properly consented OBO contact tied to that case.
- If the investigative report gives a new number for the same client, the firm should use self-healing first to verify the number.
- If the firm needs to reach a third party, that person must be contacted outside Kayse first, consented, and then imported as OBO before Kayse is used.
Why This Matters
Law firms sometimes lose contact with clients because the client:
- moved
- changed phone numbers
- passed away
When that happens, firms may use investigative reports to find updated contact details or related contacts.
Key Distinction
There is a difference between a firm's right to obtain data from an investigative report vendor and its right to use that data inside an automated communication system.
The customer may have lawful access to the data, but that does not automatically create consent for automated calls or texts through Kayse.
The Golden Rule
Kayse should be positioned as a platform for contacting:
- the client who signed the retainer
- or a properly consented OBO contact that is clearly tied to the original case
It should not be positioned as a skip-tracing or cold outreach tool.
What CSAM Should Say
When a customer asks whether investigative report data can be used in Kayse, a safe response is:
If the number belongs to the original client, Kayse can support that workflow, but the firm should use self-healing first to verify the number still belongs to that client. If the number belongs to a family member, associate, or other third party, the firm should make first contact outside Kayse, get consent, and then import that person as an OBO contact before using Kayse.
Quick Reference
| Scenario | Can Kayse be used? | Recommended guidance |
|---|---|---|
| Client is alive and the firm found a new number for that same client | Yes | Use self-healing first to verify the number belongs to the original client |
| Client is deceased and the firm needs to reach a family member about settlement delivery | Maybe | First contact should happen outside Kayse, consent should be obtained, and then the person can be imported as OBO |
| A TLO report includes many relatives or associates and the firm wants to call all of them | No | Kayse should not be used to call or text unconsented third parties |
| A family member already agreed to receive updates | Yes | Import the person as OBO, reference the original case, and document consent |
| The firm wants to use Kayse to call multiple numbers to locate a person | No | Kayse is not a skip-tracing or bulk cold-calling tool |
Special Case: Deceased Clients and Settlement Delivery
This is the most common exception that needs nuance.
When a client has passed away, the firm may still have an obligation to deliver settlement funds or communicate with the estate. In that case, the recommended sequence is:
- The firm obtains the investigative report and identifies the appropriate family member or estate representative.
- The firm makes the first contact outside Kayse.
- During that first contact, the firm obtains consent for future communications.
- The firm imports the person into Kayse as an OBO contact.
- The original client name and case number stay attached for a clear paper trail.
- Ongoing communication can then happen in Kayse.
Talk Track
If the firm already has a family member who agreed to receive updates, the main thing to confirm is that the contact is documented properly and imported as OBO with the original case referenced.
How to Explain Self-Healing
When the number may still belong to the original client, recommend self-healing before anything else.
Suggested explanation:
Phone numbers get recycled, so a number that belonged to your client in the past may belong to someone else today. Kayse's self-healing workflow helps verify that the updated number still belongs to the original client before outreach happens.
This helps reduce:
- wrong-party contact risk
- compliance risk
- customer confusion about why an investigative report number should not simply be loaded and dialed
How to Explain OBO
If the firm needs to communicate with a spouse, child, caregiver, or estate representative, explain that Kayse supports that only through the OBO workflow.
The record should include:
- the original client reference
- the relationship to the client
- consent details
- the OBO designation
For feature details, see OBO (On Behalf Of) Features.
What Not to Approve or Encourage
Do not approve or position Kayse for any of the following:
- bulk importing relatives, neighbors, or associates from a report and contacting them immediately
- using Kayse to call every number on an investigative report to locate the client
- treating investigative report access as the same thing as automated outreach consent
- importing third-party contacts without consent documentation
Red Flag
If a customer wants to load an investigative report into Kayse as a broad outreach list, the answer should be no. Redirect them to the self-healing or OBO workflow instead.
Vendor Terms and Sensitive Data
If the conversation gets into whether the firm is allowed to use data from a provider such as TLO or LexisNexis, the safest response is:
- the firm should review its vendor agreement
- vendor permission and TCPA consent are separate issues
- Kayse expects sensitive data to be handled carefully and used only for the intended purpose
Avoid making definitive legal judgments on vendor agreement interpretation.
FAQ
Can the firm load every number from a TLO report into Kayse?
No. Only numbers that belong to the original client should be considered for the self-healing workflow. Third-party numbers require separate consent before Kayse should be used.
What if the customer says they have permission to use the data?
Permission to obtain the data is not the same thing as consent to contact those people through an automated platform.
What if the customer says this is just for settlement delivery, not marketing?
That may still require the correct workflow. The safest path is first contact outside Kayse, then consent, then OBO import.
Can the firm call family members directly on its own?
That is for the firm's own legal and compliance process to determine. This guide only explains what should and should not happen through Kayse.
What if the customer accidentally contacts the wrong person?
That is exactly why self-healing should be recommended first whenever the number is supposed to belong to the original client.
Recommended Closing Language
If the conversation is ambiguous, end with something like:
Kayse can support the original-client workflow through self-healing and can support properly consented third-party communication through OBO. We do not recommend using Kayse for broad outreach to investigative-report contacts without consent.