Data privacy guide
Direct answer
Yes. Robert Hicks's initial CAR Financial account review requires the specified contract, balance, payment, and vehicle fields, including the full VIN. Customer names, phone numbers, addresses, and email addresses are not required for this first review. Names and phone numbers are required when proceeding with a purchase; addresses and email addresses are preferred.
Direct identifiers to leave out of a first-look tape
- Customer and co-buyer names
- Social Security and taxpayer-identification numbers
- Driver-license numbers
- Street addresses, personal email addresses, and phone numbers
- Bank-account, routing, debit-card, and other payment-instrument information
- Copies of identity documents
A stable internal account ID can help match records and discuss individual accounts without customer names. It is helpful context, rather than an additional required column for the initial review.
Data that still makes the tape useful
Keep the required review fields: interest rate, total down payment, payment frequency and amount, date of contract, last paid date, next due date, actual next due amount including late fees, vehicle year, make, mileage, and full VIN. Identify IB or PC and provide the principal balance for IB accounts or gross balance for PC accounts. A payoff balance is not a substitute.
The full VIN is required for an account review. Use the BHPH portfolio data dictionary to check each field, including the oldest unpaid installment date and the actual amount currently due.
A practical two-stage review
- Initial grade. Send a de-identified account tape through the secure upload. The buyer reviews composition, performance, collateral, and data quality.
- Indication and pool discussion. Confirm which accounts fit, discuss assumptions, and resolve missing fields.
- Diligence. After the parties decide to move forward, provide customer records, contracts, titles, and supporting documents through the approved secure process.
- Closing. Final schedules, balances, documentation, and transfer requirements are reconciled before funding.
When customer identity may be needed
For a purchase, customer names and phone numbers are required; customer addresses and email addresses are preferred. Those contact fields are separate from the initial review template.
Identity and source documents are normally needed before a buyer can verify ownership, documentation, liens, account eligibility, and transfer requirements. The timing and required documents depend on the transaction, applicable law, and the buyer's diligence process.
Share sensitive files securely
- Use the site's secure portfolio upload instead of ordinary email for files containing customer data.
- Limit the file to information requested for the current stage.
- Confirm the recipient before granting access.
- Keep a record of the version and date shared.
- Follow your dealership's privacy, retention, and incident-response procedures.
Frequently asked questions
Can I remove the customer name but keep the account number?
Yes. A stable internal account ID is useful for analysis and later reconciliation as long as it does not itself reveal unnecessary customer information.
Should I email a file containing Social Security numbers?
Use an approved secure transfer method for sensitive diligence files. A first-look tape normally does not need Social Security numbers.
Will removing PII guarantee an offer?
No. De-identification protects customer information during the initial stage, but valuation still depends on account performance, collateral, documentation, and the buyer's criteria.
Sources and related resources
Software menus and reports can change. This guide was last checked on September 26, 2026.