Identity Theft and Data Protection

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1 Identity Theft and Data Protection As keepers of student, faculty, and staff information, we as an institution are obligated and regulated by state and federal laws to protect certain pieces of information. This training will go over specific Federal and State laws that regulate this information, what your role is, and the penalties you or the institution may incur should we not follow these regulations. Federal Laws that Protect Information There are a variety of Federal laws that we are aware of, but there are several others that we may not be aware of. Let s review these laws. FERPA The Family Education Rights and Privacy Act (FERPA) was created in 1974 to protect private student educational records. UB must abide by FERPA regulations because it receives funds under programs administered by the Secretary of Education. The following issues are addressed within FERPA: The types of information protected as a part of the educational record, The types of information that may or may not be disclosed by an institution, Student rights regarding personal educational records, Parents rights regarding the educational records of a child, Guidelines for student written consent of disclosure, and Institutional responsibilities regarding dissemination of FERPA guidelines. Educational Records An educational record is any information directly related to a student that is maintained by an institution or by an agency acting on the institution's behalf. Educational records may only be retained as a memory aid for employees and should not be accessible outside the institution. Educational records may be in any format, including computer records, printed or hand written records, audio, photographs, film, and even . The following types of information are not considered educational records under FERPA: Notes from individual staff or faculty members that are retained for private use, Employment records, Campus police or other law enforcement records, Medical records, Alumni records unrelated to the person s role as a student (e.g. their professional accomplishments after graduation), or Statistical data that contains no personally identifiable information about specific students Any other information concerning a specific student is considered part of that student's private educational record and is subject to FERPA guidelines. Last Updated: March 23,

2 Types of Educational Records There are two types of educational records defined within FERPA: directory information and nondirectory information. Each type of record is offered a different level of protection. Directory information is defined as information within a student record that would not be considered harmful or an invasion of privacy if disclosed. Unless otherwise notified in writing, the University will release directory information upon request. That is, directory information may be disclosed by the institution without written permission from the student and may include: Name, Current Address, Phone number, address, Dates of attendance, Degree(s) and Awards received, Major or field of study The University will also publish a student s name, major field of study, and address in its Internetaccessible directory. A student may limit the disclosure of their student information in writing or electronically at: A student s directory indicator can be found on the Student Services Ctr (Student) page. If you see a this means the student has applied the FERPA restriction. Upon admission to UB, the directory indicator for a student is automatically defaulted to N (No), meaning that UB has permission to release directory information. If the student wants to reverse the directory information release to Y (Yes), he or she must notify the Office of the Registrars via an online form located at: This can be done at any time and as many times as necessary. However, it is important that the student consider very carefully the consequences of a decision to withhold directory information. Should the student elect not to authorize the release, all future requests for contact information from UB persons (on non essential matters) and from non institutional persons and organizations (such as scholarship organizations; prospective employers) will be denied. If, at the point of graduation, a student wishes to allow release of information after previously having a release indicator of Y, the student must notify the Office of the Registrar in writing. Non directory information is defined as any information not considered directory information and which may not be disclosed to anyone without prior written permission from the student. Examples of non directory information include: Social security numbers Student identification number Race, ethnicity, and/or nationality Gender Transcripts or grade reports Admissions information Coursework and class schedule Financial Aid records Disciplinary records Last Updated: March 23,

3 Employees at any institution may only access non directory information if it is required for legitimate academic reasons within their job description. Student Rights Under FERPA Eligible students, or students who have reached the age of 18 and/or attend school beyond the high school level, have certain rights regarding their own educational records under FERPA. A student has the right to know what information is held by the institution and for what purpose that information is retained. A student may also: access his or her educational records kept by the school, demand that his or her educational records be disclosed only with consent, amend his or her educational records, and file complaints if an institution discloses educational records in violation of FERPA. In order for any protected non directory educational information to be disclosed to a party outside the institution, a student must provide a statement of written consent. According to FERPA, that statement must include: a description of the records to be disclosed the purpose of the disclosure the party or class of parties to whom the disclosure is to be made the date the signature of the student whose record is to be disclosed the signature of the custodian of the educational record. Parental Rights Under FERPA Parents have certain rights regarding educational records of their children under FERPA. However, these rights transfer to the student once he or she reaches the age of 18 and/or attends school beyond the high school level. Under FERPA, a parent does not have an automatic right to view their children s postsecondary education records. FERPA does allow release of information to parents of college students when the student is a dependent for tax purposes; in a health or safety emergency, in certain drug and alcohol incidents, and in addition, may disclose law enforcement records to anyone when the records kept by the campus security office are kept solely for law enforcement purposes. The guidance also notes as follows: Nothing in FERPA prohibits a school official from sharing with parents information that is based on that official's personal knowledge or observation and that is not based on information contained in an education record. Therefore, FERPA would not prohibit a teacher or other school official from letting a parent know of their concern about their son or daughter that is based on their personal knowledge or observation. Last Updated: March 23,

4 Disclosing and Withholding Information Students do not have full access to any information within their record. Students may not access: Financial information submitted by parents, Confidential information included in the file before 1/1/75, Confidential information associated with administrative functions within the institution (such as admissions, employment, job placement or honors) to which a student has waived rights of inspection and review, or Educational records containing information about other students You may legally disclose information without consent to the following parties or under the following conditions: School officials with legitimate educational interest Other schools to which a student is transferring Specified officials for audit or evaluation purposes Appropriate parties in connection with financial aid to a student Organizations conducting certain studies for or on behalf of the school Accrediting organizations To comply with a judicial order or lawfully issued subpoena Appropriate officials in cases of health and safety emergencies; and State and local authorities, within a juvenile justice system, pursuant to specific State law (officials must have appropriate subpoenas or warrants). Penalties for not Complying with FERPA All educational agencies or institutions that receive funds under any program administered by the Secretary of Education must abide by FERPA regulations, which include: Compliance of disclosure laws for directory and non directory information Compliance with requirements for any statements of written consent In addition, institutions under FERPA are required to annually publish FERPA guidelines and make those guidelines available to students and parents. Failure by an agency or institution to abide by FERPA regulations may result in lawsuits or loss of federal funding. Individuals responsible for non compliance may be subject to: Confinement in the county jail not to exceed 6 months and/or Fine not to exceed $1,000 Last Updated: March 23,

5 Last Updated: March 23,

6 HIPPA The Health Insurance Portability and Accountability Act (HIPAA) was signed into law in 1996, in part, as a response to concerns regarding confidential health information. HIPAA s overall purpose is to: Provide continuity and portability of health benefits to people in between jobs. Ensure security and privacy of individual health information. Reduce administrative expenses in the healthcare system; administrative costs have been estimated to account for nearly 25% of healthcare costs. Provide uniform standards for electronic health information transactions. Provide measures to combat fraud and abuse in health insurance and health care delivery. What HIPAA Means to You Laws and procedures establish expectations; ultimately, laws and procedures must be carried out and observed by people. This means successful implementation of HIPAA in the New York State workplace relies on YOU. New York State is not alone in implementing the rules around HIPAA. Across the country, public employees who are providing care or government agencies that pay for care are gearing up for HIPAA s implementation. HIPAA Is This For Me? You might be asking yourself, "I don t work in healthcare. Do I have to worry about HIPAA?" HIPAA mandates that employees who handle protected health information receive training on the basics of HIPAA s provisions. HIPAA will affect how you: Handle health information as part of a Covered Entity. Carry out and ensure patient confidentiality, and maintain security of information. Request or obtain health information. Share health information with others. What You Need to Know This program provides only an overview of HIPAA s requirements. Specific questions regarding your job responsibilities should be brought to the attention of your supervisor. In the future, you will need to: Avoid sharing health information with co workers who may not have a "need to know." Avoid discussing health information in public areas, or in telephone conversations that can be easily overheard by others. Keep and protect written health information in the work environment from the eyes of others who do not need the information in order to perform their assigned job. Make sure that casual visitors can t wander into areas in which clinical or billing information is kept. Recognize when health information about a person can be shared without the person s permission, and when written or oral permission of the person is required. Last Updated: March 23,

7 Make sure that if you have access to confidential or private information about a person, you follow all policies or procedures for safeguarding the confidentiality of that information. Protected Health Information The HIPAA privacy rule covers and sets standards for the collecting, sharing and storing of a person s Protected Health Information, or PHI, for short. PHI is information that: Relates to past, present or future physical or mental health or condition, payments and provisions about healthcare. Identifies the individual in a personal way. Provides a reasonable basis to be used to identify the individual. HIPAA A Quick Review HIPAA is a federal law, part of which establishes standardized procedures for the protection of private health information. HIPAA will affect many employees, and those working in healthcare will be affected the most. Organizations that are covered by HIPAA are called Covered Entities and include: Health Plans, Healthcare Providers and Healthcare Clearinghouses. New York State agencies that pay for health care, provide healthcare while doing business electronically, or who are healthcare clearinghouses are Covered Entities. The specific information that is protected under HIPAA is referred to as Protected Health Information or PHI. PHI is information that individually identifies the person and contains health information and was created or received by a Covered Entity. Last Updated: March 23,

8 Deter, Detect, and Defend Against Identity Theft: Red Flags Training University at Buffalo Introduction This course is designed to introduce you to the University at Buffalo s Identity Theft Prevention Program, as it relates to compliance to the Red Flags Rule. Objectives Define Identity Theft and determine the need for an Identity Theft Prevention Program Identify which Red Flags are relevant for Vice Provost and Enrollment Management Services Offices Identify and respond to relevant Red Flags Regulation Are enforced by the Federal Trade Commission (FTC), the federal bank regulatory agencies, and the National Credit Union Administration Set out how certain businesses and organizations must develop, implement and administer their Identity Theft Prevention Program. All procedures must be fully implemented by 12/31/2010. As many as nine million Americans have their identities stolen each year. Identity thieves may drain their accounts, damage their credit, and even endanger their medical treatment. Federal Trade Commission, Fighting Fraud with the Red Flag Rule Last Updated: March 23,

9 Who Must Comply with These Rules? Financial Institutions and Creditors must comply. Although the University at Buffalo is not a financial institution, we are a creditor because we regularly defer payment for goods or services or provide good or services and bill customers later. (Ever get a bill from the Office of Student Accounts? The definition further describes covered accounts. These are accounts where there may be a foreseeable risk of identity theft. This is particularly true if the account can be accessed remotely, such as through the Internet or telephone. In thinking about identity theft, we must go beyond accounts at the University at Buffalo and think about things like, Admissions, Financial Aid, and Employment Applications. All can send up a red flag. Covered Accounts A Covered Account is any account that the University at Buffalo offers or maintains: Primarily for personal, family, or household purposes, or That permits multiple payments or transactions, or For which there is a reasonably foreseeable risk of identity theft Based on a Risk Assessment, it was determined that VPEM offers the following types of covered accounts as defined by the regulation: Student Loans UB Time Payment Plan UB Direct Deposit Deferred Payments Last Updated: March 23,

10 Compliance is a Four Step Process Step 1 Identify Relevant Red Flags Step 2 Detect Red Flags Step 3 Prevent and Mitigate Identity Theft Step 4 Update your Program Step 1 Identify Red Flags There are five different categories of identifying red flags: 1. Notifications and Warning from Credit Reporting Agencies 2. Suspicious Documents 3. Suspicious Personal Identifying Information 4. Suspicious Covered Account Activity or Unusual Use of Account 5. Alerts from Others Category 1: Notification and Warnings from Credit Reporting Agencies Most VPEM units do not request credit reports on a regular basis. If your unit does use credit reports for whatever reason, Red Flags may include: 1. Report of fraud accompanying a credit report 2. Notice from a credit agency of a credit freeze 3. Notice from a credit agency of an active duty alert 4. Receipt of address discrepancy in response to a credit report request 5. Indication from a credit report of activity inconsistent with an applicant s usual pattern or activity. Last Updated: March 23,

11 Category 2: Suspicious Documents Almost all of VPEM with covered accounts work with some form of documentation. These documents may include employment applications, applications for admissions, taxation and revenue documentation and change of address request. Red flags include: 1. Identification document or card that appears to be forged, altered or inauthentic 2. Identification document or card on which a person s photograph or physical description is not consistent with the person presenting the document 3. Other document with information that is not consistent with existing student/employee information; and 4. Application that appears to have been altered or forged. Category 3: Suspicious Personal Identifying Information When dealing with individuals at the University at Buffalo, proper identifying information is needed. This includes a UB ID, a driver s license, or passport. On the phone employees should verify the birth date or other personal information (e.g. What class(es) do you have on Monday s this semester?). This doesn t stop with student contact as described below: 1. Identifying information presented that is inconsistent with other information the student provides (example: inconsistent birth dates) 2. The social security number has not been issued or is listed on the Social Security Administration s Death Master File 3. A person fails to provide complete personal identifying information on the application when reminded to do so 4. Identifying information presented that is consistent with fraudulent activity (such as a invalid phone number or fictitious billing address) Last Updated: March 23,

12 Category 4: Suspicious Account Activity or Unusual Use of Account Any of the following should be considered a Red Flag. Use your own judgment. Is there anything else specific to your unit that may cause concern? For example, a student charging only electronic devices (e.g. ipods or laptop computer) to their UB Micro Account. 1. Change of address on account followed by a request to change the student s name 2. Payments stop on an otherwise up to date account 3. Mail sent to a student is repeatedly undeliverable although there is account activity. 4. Notice to UB that the student is not receiving any UB mail 5. Notice to UB that the account has unauthorized activity 6. Unauthorized access to or use of student account information 7. Breach in UB s computer system security (Hub, MyUB, etc.) Category 5: Alerts from Others An obvious Red Flag occurs whenever notice is given to UB from a student, identity theft victim, law enforcement agency, or other person that UB has opened or is maintaining a fraudulent account for a person engage in identity theft. Last Updated: March 23,

13 Step 2: Detect Red Flags Now that you know what a Red Flag looks like, it s time to come up with procedures specific to your unit to detect Red Flags. Two areas of particular concern are: 1. Obtaining identifying information about, and verifying the identity of a person opening/maintaining a covered account. This is as simples as requesting a picture ID anytime a student transacts business with your unit. 2. Authenticating customers (e.g. requiring a logon ID and password if online or verifying birthday and/or class schedule by phone), monitoring transactions and verifying the validity of change of address requests. For example, the Office of Student Accounts will not change account addresses. Students are directed to do this online as a logon ID and password are required for authentication. Step 3: Prevent and Mitigate Identity Theft In the event UB personnel detect any identified Red Flags, these individuals should discuss the situation with your supervisor who will take one or more of the following steps, depending on the degree of risk posed by the Red Flag: Complete the Red Flags Incident Report Form Complete the Complaint of Privacy Breach Form Continue to monitor an account for evidence of identity theft Contact the student or applicant Change passwords or other security devices that permit access to the account Not open a new account/admit student Provide student with a new ID number Notify your unit Director Notify law enforcement Determine that no response is warranted under the particular circumstances. Last Updated: March 23,

14 Protect Student/Employee Identifying Information Ensure that any UB website/file directories containing confidential information is secure and has the appropriate permissions to allow access to those directories Ensure complete destruction of paper documents and computer files containing student account information when a decision is made to no longer maintain such information Ensure office computers with access to account information are password protect, and has a VPN client installed on them. Should you leave your desk, please lock your computer (no exceptions!) Avoid use/asking for social security numbers Ensure computer virus protection is up to date Require and keep only the kinds of student/employee information that are necessary for University purposes. Keep information in secured locations in your office. Step 4: Update the Program Per the University at Buffalo s Identity Theft Prevention and Red Flags Policy Departmental Red Flags Rule Contact Person will annually review the departmental Red Flags Rule Procedures to identify new Covered Accounts, changes to existing Covered Accounts, and changes in procedures for detecting, mitigating, and preventing identity theft. Each unit working with covered accounts must implement policies and procedures related to identifying, detecting, mitigating, and preventing identity theft. In addition, a detailed report of all incidents of identity theft and suspicious behavior that may be related to identity theft must be submitted to the Red Flags Program Administrator. At UB, this person is the Associate Vice President and Controller. Our environment changes constantly. Technological advances and the ability to conduct most business online makes it imperative that individual departmental policies and procedures be reviewed and updated periodically. Know your environment! Know your customers! Know your risk! Last Updated: March 23,

15 Example of an Incident Mary works in the Office of Student Accounts. She receives a call one day from a student requesting information on a refund check that should have been mailed to her weeks ago. Mary, according to Office of Student Accounts procedures, asks the student to verify her birth date and asks her what courses she is taking the current semester. The student provides information that matches the system data. Mary determines that a refund check was issued two weeks ago. She looks up the mailing address and asks the student to verify this address. The two addresses do not match. The address the student provides was inactivated when a new address was entered. Upon further investigation, the address was not changed online by the student but by another department at UB. Mary sees a Red Flag. She informs the student she will look into the matter further and someone will call her back. Immediately she reports the Red Flag to her supervisor. Her supervisor looks into the matter and finds that the check was cashed but the signature on the copy of the cancelled check does not match any other signatures on prior checks or other UB documentation signed by the student. What happens next? Last Updated: March 23,

16 Answer Mary s supervisor determines that this is definitely a possible identity theft situation. She contacts the student, prepares a written report and contacts the University Police Department. The University Police Department will contact the potential identity theft victim (student) and investigate fully. Mary s supervisor also completes the Red Flags Incident Report form and submits it to The Red Flags Program Administrator, 420 Crofts Hall, North Campus Further Information: The department that changed the address should have asked for other documentation showing the new address and a photo ID as verification of the identity of the individual and evidence of a valid address. Or, the student should have been directed to change the address online with a logon ID and password. The student will be issued another check. Because the signature is not hers, an affidavit must be completed and submitted to the bank, but she will receive a replacement check. Further Examples Suspicious Personal Identifying Information Identification document or card that appears to be forged, altered or inauthentic; Identification document or card on which a student or patient s photograph or physical description is not consistent with the person presenting the document; Identifying information presented that is inconsistent with other information the student or patient provides (for example, inconsistent birth dates); Identifying information presented that is inconsistent with other sources of information (for instance, an address on identification not matching an address in the student system); Identifying information presented that is the same as information shown on other applications that were found to be fraudulent; Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address); Social security number presented that is the same as one given by another student or patient; An address or phone number presented that is the same as that of another student or patient; A student or patient fails to provide complete personal identifying information on an application when reminded to do so (however, by law social security numbers must not be required); A student or patient s identifying information is not consistent with the information that is on file for the customer; and A student or patient who has an insurance number but never produces an insurance card or other physical documentation of insurance. Last Updated: March 23,

17 Suspicious Documents Identification document or card that appears to be forged, altered or inauthentic; Identification document or card on which a student or patient s photograph or physical description is not consistent with the person presenting the document; Notifications and Warnings from Credit Reporting Agencies Report of fraud accompanying a credit report; Notice or report from a credit agency of a credit freeze on a customer or applicant; Notice or report from a credit agency of an active duty alert for an applicant; and Indication from a credit report of activity that is inconsistent with a customer s usual pattern or activity. Suspicious Account Activity or Unusual Use of Account A complaint or question from a student or patient based on the person's receipt of: o a bill for another individual; o a bill for a product or service that the student or patient denies receiving; o a bill from a higher education institution or health care provider that the student or patient never patronized; o a notice of insurance benefits (or Explanation of Benefits) for services never received. Change of address for an account followed by a request to change the account holder's name; Payments stop on an otherwise consistently up to date account; Account used in a way that is not consistent with prior use (for example, very high activity); Mail sent to the account holder is repeatedly returned as undeliverable; Notice to the University that a customer is not receiving mail sent by the University; Breach in the University s computer system security; Notice to the University that an account has unauthorized activity; Unauthorized access to or use of student account information; and A notice or inquiry from an insurance fraud investigator for a private insurance company or a law enforcement agency. Alerts from Others Notice to the University from a customer, identity theft victim, law enforcement or other person that it has opened or is maintaining a fraudulent account for a person engaged in Identity Theft. Further Links of Interest All employees viewing or editing any type of student or employee data should complete the Handling Data Safely Course. Instructions can be found at data.php Report privacy issues through an sec (Use the Complaint of Privacy Breach Form) The University at Buffalo s Red Flags Identity Theft Prevention Policy can be found at: Last Updated: March 23,

18 UB Policies Related to Identity Protection Access to Information Compliance Form: pdf UB Computer and Network Acceptable Use: Data Classification Standard: All university data must be classified into one of 4 categories described in this standard and protected using security measures consistent with the minimum standards for the classification level as described in related information/data security policies pdf UB Information Security: Data Access and Security Policy: pages.pdf Privacy: policies/privacy.pdf Securing Network Connected Devices: Protecting Regulated Private Data: Social Security Number Policy: Computer log policy: UB Modifications to NYS Information Security Policy: UBIT Password: policies a to z/ubit password/_jcr_content/par/assetcolumn/assets/relateddownload/file.res/ub PasswordPolicy pdf Last Updated: March 23,

19 Reference Material Last Updated: March 23,

20 Last Updated: March 23,

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