Date Posted: 05/02/2024

UKG & Equifax Want to Monetize Your Data
What You Need to Know

This document is intended to share with you some recent updates related to UKG and its evolving partnership with Equifax The Work Number (TWN), which now includes a TWN service “Auto Enrollment” through which many of you have been unknowingly impacted. Many of you partnered with Vault Verify because of our commitment to employee data privacy and our innovative approach to providing the most accurate, real-time, and secure solution on the market. Unfortunately, recent tactics by UKG in partnership with TWN has a notable and negative impact on our ability to continue to provide you with the level of service you have come to expect. The following summarizes the nature of the partnership and the level to which your data may already be unknowingly provided to TWN, as well as steps you can take to protect yourself. 

UKG/TWN Partnership Background

In 2022, UKG entered into a partnership agreement with Equifax The Work Number (TWN) to offer verification services to UKG customers. Until recently, that agreement largely entailed UKG referring customers to TWN. In Q4 2023, UKG changed tactics to embed the service more aggressively via an OEM relationship and an “auto enrollment” campaign. Here’s what we know:

1. UKG is financially incentivized via an annual royalty, paid by Equifax, for every employee record it passes on to TWN. The more employers (and thus employees) enabled, the more revenue to UKG. 

2. The partnership from Equifax requires that UKG configure the TWN service so that UKG customers (employers) will be auto enrolled by default and, therefore, must intentionally opt out of the offering. Once enabled, 100% of your employment and payroll history from within your UKG environment is immediately extracted and copied into the TWN database. Your company will be searchable in TWN’s database, and your employees will be reportable. The shared data set includes all current and former employees and their employment and income details. Start/end dates, locations, job titles, pay history, etc. … 

3. Through a series of rollouts starting in Q4 2023, a subset of UKG customers have been targeted and the service enabled, including Vault Verify customers using UKG. We’ve asked UKG to provide us with specific customers’ names so that we can work more closely with you to remediate the situation, but they’ve thus far been unwilling to share the list with us. They have indicated that more groups of customers are planned for 2024. 

It is important to note that Vault Verify’s insistence on bringing clarity and guidance to our mutual customers has resulted in UKG terminating the long-standing partnership with Vault Verify. This termination has no meaningful impact on our service nor will it affect our customers’ consistent positive experiences. Vault Verify remains a terrific choice, with several hundred UKG customers happily configured and utilizing the platform. 

Why is Auto Enrollment into TWN a Bad Thing?

We are not here to comment specifically on the pros and cons of a competitive solution. There is no shortage of media coverage about Equifax’s aggressive data acquisition and monetization strategies. Many of you have had prior experience with TWN and switched to Vault Verify on the heels of that experience. Still, some of you may have no such prior experience or may be thinking that it can’t hurt to have a second offering. Beyond the contractual exclusivity that exists between your company and Vault Verify – a contract that UKG and TWN have willfully neglected – there are several negative consequences to running Vault Verify and TWN in parallel. Notably:  

1. Misconfiguration – The vast majority of Vault Verify customers have some form of configuration in place. These configurations often provide custom disclaimers to verifiers, provide a more accurate mapping of earnings to align with your company’s compensation model, or explicitly exclude certain employee groups from being reportable. In all cases, these configurations are aimed at providing the verifier with more information to avoid costly and time-consuming follow-ups from the verifier to HR. None of these configurations is known or honored by the UKG/TWN integration. Perhaps most concerning – if you have been auto enrolled into this service and also have excluded specific individuals from being reportable via Vault Verify, those individuals are now accessible via TWN. 

2. Troubleshooting Confusion – With Vault Verify as your sole provider, we pride ourselves on being readily available for any questions that arise from a verification report that’s been provided from our platform. Because of our configurability and real-time APIs, it doesn’t happen often…but when it does you know that we take an active role in any remediation. With TWN enabled on your account, you will now have to decipher the source of a report. Many Vault Verify customers cite from prior experience a notable increase in follow-ups for reports sourced from TWN, mainly due to the lack of configuration referenced above.  

3. Lower Revenue Share – All Vault Verify customers are enrolled in our revenue share program, wherein Vault Verify pays employers a portion of the revenue we collect from commercial verifications. We use the revenue share as a natural incentive to drive ongoing internal communication and adoption of the Vault Verify service. You may use it to fund various initiatives for HR, such as continuous learning or conference fees. Some employers even route the revenue to charitable organizations. Regardless of how you utilize those funds, with the introduction of TWN and the relationships they’ve developed with banks, some verifications that would otherwise find their way to Vault Verify will be serviced by TWN. In short, your revenue share will decrease. 

How Do I Know If I’ve Been Auto Enrolled in the UKG/TWN Service?

We asked UKG to provide us with a list of Vault Verify customers who have been auto enrolled in the service. They declined to provide us with that list, citing NDA concerns with Equifax. However, through our investigation, we’ve identified a few different ways to determine if the service is enabled. 

1. Look For Emails – You or one of your peers would have received at least two emails regarding the service. We are aware of one wave of rollout wherein the introductory email was sent on October 26, 2023, and the activation email on December 20, 2023. However, there have been subsequent rollouts. 
   1. Introductory Email – An email with the title “Coming Soon! Easily automate employee verifications” was sent from [email protected] and included a high-level summary of the partnership. The email ended with a message indicating that “No action is needed at this time. An Equifax implementation representative will be reaching out to you in the coming weeks with a few simple steps to get you started.” For the companies targeted thus far, the email was purportedly sent to all users configured as UKG system admins.
   2. Activation Email – A subsequent email with the title “You are Live on the UKG Employment and Verification Service powered by The Work Number. Please open for important information” was sent from [email protected]. This email is your onboarding email, complete with a TWN company code. According to joint UKG/Vault Verify customers we’ve engaged thus far, the service was enabled without any follow-up conversation with a UKG or Equifax representative, despite what was promised in the first email. This email was likely sent to only one of the people who received the first email. It is unclear from UKG who from each company would have been targeted with this email. 

2. Look For Service Account – Much like Vault Verify, the TWN integration relies on the creation of a service account. For those who were auto enrolled, UKG support proactively went into your account and configured this service account. To find the service account: 
   1. Navigate to ‘System Configuration’ and select ‘Service Account Administration’.  
   2. You will see a list of service accounts. Search for a service account with the words EFX, Equifax, TWN or The Work Number. It should be fairly obvious. 

3. Search TWN – Click this link to access The Work Number – Find Employer  page. Here, you can enter your company name to see if there’s a match. It is important to note:
   1.  TWN may not be referencing your name exactly as you would like it referenced, so you should try different variations, formerly known as, or subsidiaries. 
   2. A match does not mean you were recently added. In many cases, TWN will keep your company searchable even if they only have historical data. 

4. Ask UKG – You may want to try this first, but from the few conversations we’ve had with Vault Verify customers who have been auto enrolled, your results may vary. In some cases, it has taken weeks to even confirm enrollment. Still others have received confusing or misleading information about the reality of the service activation.
   1. Open a ticket with UKG Support  
   2. Email or include on the ticket the following people: 
      
      1. Your UKG Representative 
      2. UKG Partnership Team Overseeing the TWN Auto Enrollment program 
         
         1. Mike May – [email protected] (VP Technology Partner Program) 
         2. Matt Hammack – [email protected] (Director of Strategic Alliances)
         3. Bill Taylor – [email protected] (Partner Alliance Director)

What Should I Do If TWN Is Enabled?  

If TWN has been enabled on your UKG account, follow these steps to cancel:  

1. Deactivate the Service Account Immediately – The UKG/TWN data sync cannot function without the service account. Deactivating the account will cease any further data syncing in the near term, but you must complete the remaining steps or else risk the service being re-enabled on your account. 

2. Complete UKG’s Opt-Out Form – Opt-out of the Equifax/TWN offering by completing this form provided by UKG. At the bottom of the form is a text box where you can supply additional notes. We recommend including a note such as:

Recommended message draft for your convenience:

3. Email UKG Support – Open a ticket with UKG and deliver the same message.

4. Email UKG ERM – Send an email to your account rep with the same message.

I’ve Deactivated The Service. Am I Safe?  

Unfortunately, the short answer is “No”. While UKG has committed to Vault Verify that they will honor customer cancellation requests, two issues remain. 

1. Equifax Continues to Monetize Your Data – UKG’s cancellation of the service will stop future data transmissions and should remove your company name from being searchable on TWN. However, any data captured while the service was enabled will remain within TWN and will be tied to your individual employee’s ongoing record. Customers have told us that it usually requires the involvement of General Counsel to force TWN to expunge the data. 

2. Ongoing UKG Efforts to Auto Enroll – UKG has made it clear to Vault Verify that they will continue to heavily market this service to their customer base any chance they get. This includes, but is not limited to, adding TWN service as a line item by default on all contract renewals, sales orders, and other contract add-ons. 

Simply put, you must remain vigilant since there is no formal process we are aware of wherein the demands you make to UKG to be excluded from auto enrollment are guaranteed to be honored. And frankly, UKG is heavily incentivized to enable the service, as they are paid for every employee onboarded into TWN. We recommend the following additional steps to heighten awareness of this issue internally: 

1. Educate Procurement – They should be on the lookout for any auto enrollment language, as well as additional services added to order forms that are not explicitly OK’d by the internal decision maker. 

2. Talk to Legal and Governance, Risk, Compliance – Whether you operate in California or one of the 20 or so other states with data privacy legislation enacted or in progress, your legal and GRC departments will want to be made aware of the potential risk and exposure to which UKG has opened your organization. They will likely also want to review any messaging/demands you make of UKG, per the template notice provided above. 

3. Spread The Vault Verify Word – Double down on efforts to ensure that all office managers, HR managers, and employees direct verification requests to Vault Verify. Vault Verify Support can help you with various best practices to spread the word, including: 
   1. Updates to your “Contact Us” web page to provide clear instructions to verifiers 
   2. Updates to your automated telephone tree 
   3. Inclusion of a verification policy in your employee handbook that dictates usage of the Vault Verify platform to maintain proper compliance and reduce risk.