Approved by the Audit Committee of the Board of Trustees, effective February 3, 2009.

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1 Red Flag Identity Theft Policy 1.) Policy and Program Rationale: Messiah College ( College ) has developed the Identity Theft Policy ( Policy) and Prevention Program ( Program ) pursuant to the Federal Trade Commission s Red Flags Rule ( Rule ), which implements Section 114 of the Fair and Accurate Credit Transactions Act of The program was developed with oversight and approval of the Audit Committee of the Board of Trustees. 2.) Approval and Effective Date of the Policy: Based on the size of the College s operations and account systems, and the nature and scope of the College s activities the Audit Committee of the Board of Trustees determined that this Policy and Program was appropriate for Messiah College. Approved by the Audit Committee of the Board of Trustees, effective February 3, ) Definitions: Identify theft means fraud committed or attempted using the identifying information of another person without authority. Covered account means a consumer account that a creditor offers or maintains, primarily for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions. Covered accounts include, but are not limited to, credit (debit) cards, loans, and unpaid or partially unpaid student accounts. Red flag means a pattern, practice or specific activity that indicates the possible existence of identity theft. Creditor means any person who defers payment for services rendered, such as an organization that bills at the end of the month for services rendered the previous month. A college or university could be considered a creditor by participating in the Federal Perkins Loan Program, participating as a lender in the Federal Family Education Loan Program, offering institutional loans to students, faculty, or staff, or offering a plan for payment of tuition throughout the semester rather than requiring full payment at the beginning of the semester. Identifying Information is any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including: name, address, telephone number, social security number, date of birth, government issued driver s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, computer s internet protocol address, or routing code. 4.) Knowledge of this Policy and Program: All Business Office and institutional personnel with access to data related to covered accounts should be knowledgeable of this policy. 5.) Responsibilities: College s Vice President for Finance is responsible for the execution of the program. 6.) Policy: The purpose of this policy is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate the occurrence of identity theft in connection with the opening of a covered account or an existing covered account and to provide for continued administration of the Program. The Program shall include reasonable policies and procedures to: Identify relevant red flags for covered accounts offered or maintained by the College, and incorporate those red flags into the program Detect red flags that have been incorporated into the Program Approval: Board of Trustees Page 1 of 5

2 Respond appropriately to any red flags that are detected to prevent and mitigate identity theft Ensure the Program is updated periodically to reflect changes in risks to consumers and to the safety and soundness of the creditor from identity theft The Program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks. 7.) Program: The following information outlines the details of Messiah s Identity Theft Program. A.) Identification of Covered Accounts: College has identified five types of accounts, four of which are covered accounts administered by the College and one type of account that is administered by a service provider. College covered accounts: 1. Refund of credit balances involving PLUS loans 2. Refund of credit balances, without PLUS loans 3. Deferment of tuition payments 4. Emergency loans Service Provider covered account: 1. The service provider covered account is a tuition payment plan administered by Tuition Management Systems, Inc. ( TMS ). B.) Identification of Relevant Red Flags: College considers the following risk factors in identifying relevant red flags for covered accounts: Types of covered accounts offered or maintained Methods provided to open covered accounts Methods provided to access covered accounts College s previous history of identity theft College will address the detection of red flags (1) when opening new covered accounts by obtaining identifying information about and verifying the identity of a person opening a covered account, and (2) with existing accounts by authenticating persons, monitoring transactions, and verifying the validity of change of address requests. College considers the following risk factors in identifying relevant red flags for covered accounts: 1. The types of covered accounts as noted above; 2. The methods provided to open covered accounts--acceptance to the College and enrollment in classes requires all of the following information: application with student information high school transcript official ACT or SAT scores letters of recommendation entrance medical record medical history immunization history insurance card Approval: Board of Trustees Page 2 of 5

3 3. The methods provided to access covered accounts: Disbursement obtained in person requires picture identification Disbursements obtained by mail can only be mailed to an address on file 4. The College s previous history of identity theft. College identifies the following as red flags: 1. Documents provided for identification appear to have been altered or forged 2. The photograph or physical description on the identification is not consistent with the appearance of the student presenting the identification 3. A request made from a non-college issued account 4. A request to mail something to an address not listed on file 5. Presentation of suspicious or altered personal identifying information or other documents 6. Alerts, notifications or other warnings received from consumer reporting agencies or service providers 7. Notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts 8. Discrepancies in name, address, photograph or physical description on the identification being presented 9. Attempts to access an account by unauthorized users 10. Unusual use or other suspicious activity related to a covered account C.) Detection of Red Flags: 1. Student Enrollment: The Program will take the following steps to obtain and verify the identity of the person opening the account. a. Require certain identifying information such as name, date of birth, academic records, home address, or other identification; and b. Verify the student s identity at the time of issuance of student identification card (review of driver s license or other government-issued photo identification). 2. Existing Accounts: The Program will detect red flags relevant to each type of covered account as follows a. Refund of a credit balance involving a PLUS loan - As directed by federal regulation (U.S. Department of Education) these balances are required to be refunded in the parent s name and mailed to their address on file within the time period specified. No request is required. Red Flag All Red Flags as listed above in section 7.B. b. Refund of credit balance, no PLUS loan - requests from current students must be made in person by presenting a picture ID or in writing from the student s college issued account. The refund check can only be mailed to an address on file or picked up in person by showing picture ID. Requests from students not currently enrolled or graduated from the college must be made in writing and mailed to the address on file. Red Flag Picture ID not appearing to be authentic or not matching the appearance of the student presenting it. Request not coming from a student issued account as well as all Red Flags as listed above in section 7.B Approval: Board of Trustees Page 3 of 5

4 c. Deferment of tuition payment - requests are made in person only and require the student s signature. Red Flag All Red Flags as listed above in section 7.B d. Emergency loan - Requests must be made in person by presenting a picture ID or in writing from the student s college issued account. The loan check can only be mailed to an address on file or picked up in person by showing picture ID. Red Flag - Picture ID not appearing to be authentic or not matching the appearance of the student presenting it. Request not coming from a student issued account as well as all Red Flags as listed above in section 7.B e. Tuition payment plan - Students must contact an outside service provider and provide personally identifying information Red Flag All Red Flags as listed above in section 7.B D.) Preventing and Mitigating Identity Theft 1. Responses to Red Flags Detected: College will provide for appropriate responses to detected red flags in each type of covered account to prevent and mitigate identity theft. Responses may include: Monitoring a covered account for evidence of identity theft Contacting the account holder Changing the passwords, security codes, or other security devices that permit access to a covered account Reopening a covered account with a new account number Not opening a covered account Closing an existing account Notifying law enforcement Determining that no response is warranted under the circumstances Denying access to a covered account until adequate information is available to eliminate the red flag 2. Protecting Student Information: In order to prevent the likelihood of identity theft occurring with respect to covered accounts, College will take the following steps with respect to its internal operating procedures to protect student identifying information. Ensure that College s website is secure or provide clear notice that the website is not secure; Ensure complete and secure destruction of paper documents and computer files containing student account information when a decision has been made to no longer maintain such information; Ensure that office computers with access to covered account information are password protected; Avoid use of social security numbers (whenever possible) Ensure computer virus protection is up to date; and Require and keep only the kinds of student information that is necessary for college purposes. E.) Administration 1. Oversight of the Program: Responsibility for developing, implementing and updating this Program lies with the Committee on Information Security and Data Standards. The Committee on Information Security and Data Standards will be responsible for the following: Approval: Board of Trustees Page 4 of 5

5 Program administration Training College staff members on specific responsibility for the Program Reviewing any staff reports regarding the detection of Red Flags and the steps for preventing and mitigating identity theft Determining which steps of prevention and mitigation should be taken in particular circumstances Providing guidance to the Audit Committee of the Board of Trustees as to periodic changes to the Program Preparing and delivering an annual report to the Audit Committee of the Board of Trustees regarding compliance with Red Flag rules 2. Updating the Program: This Program will be periodically reviewed and updated to reflect changes in risks to students and the security of the College from identity theft. At least once per year in October, the Committee on Information Security and Data Standards will consider the College's experiences with identity theft, changes in identity theft methods, changes in identity theft detection and prevention methods, changes in types of accounts the College maintains and changes in the College's business arrangements with other entities. After considering these factors, the Committee on Information Security and Data Standards will determine whether changes to the Program, including the listing of Red Flags, are warranted. If warranted, the Committee on Information Security and Data Standards will update the Program. 3. Staff Training: College staff responsible for implementing the Program shall be trained either by or under the direction of the Committee on Information Security and Data Standards in the detection of Red Flags, and the responsive steps to be taken when a Red Flag is detected. 4. Oversight of Service Provider Arrangements: College shall take steps to ensure that the activity of a service provider is conducted in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft whenever the organization engages a service provider to perform an activity in connection with one or more covered accounts. Currently the College uses Tuition Management Systems, Inc.( TMS ) to administer the Tuition Payment Plan and the Perkins Loan. Students contact TMS directly through its website or by telephone and provide personally identifying information to be matched to the records that the College has provided to TMS. Approval: Board of Trustees Page 5 of 5

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