THE UNIVERSITY OF MICHIGAN IDENTITY THEFT PREVENTION PROGRAM
|
|
- Kevin Chandler
- 6 years ago
- Views:
Transcription
1 I. Purpose & Scope THE UNIVERSITY OF MICHIGAN IDENTITY THEFT PREVENTION PROGRAM The Identity Theft Prevention Program was developed pursuant to the Federal Trade Commission s Red Flag Rules promulgated as part of the Fair and Accurate Credit Transactions Act. The University s Program is designed to detect, prevent and mitigate identify theft in connection with the opening of a covered account or any existing covered accounts within the University s Ann Arbor, Flint and Dearborn Campuses. The Program has been designed to be appropriate to the size and complexity of the University as a creditor and the nature and scope of its activities. II. The Red Flag Rules Overview The Red Flag Rules, found at 16 CFR Part 681, require users of consumer credit reports, certain creditors and certain card issuers to take various steps to protect consumers from identity theft. Users of credit reports must respond to notices of address discrepancies and take reasonable steps to confirm the accuracy of the address it may have. A creditor must periodically determine, by conducting a risk assessment, whether it offers or maintains covered accounts. Upon identifying any covered account(s), the creditor is required to develop and implement a written Identity Theft Prevention Program designed to: A. Identify relevant Red Flags for new and existing covered accounts and incorporate those Red Flags into the Program; B. Detect Red Flags; C. Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity Theft; and D. Periodically update the program to reflect changes in risks to the account holders or to the safety and soundness of the creditor from Identity Theft. Page 1 of 6
2 A card issuer must establish and implement reasonable address verification procedures. Oversight and administration of the Program shall be performed by the Office of the Chief Financial Officer in consultation with the Provost and the Chief Financial Officer for UM Health System. Periodic reports on the progress of program implementation will be provided to the Finance, Audit, and Investment Committee of the Board of Regents. III. Definitions A. Account means a continuing relationship established by a person with a creditor to obtain a product or service for personal, family, household or business purposes. It includes (i) an extension of credit, such as the purchase of property or services involving a deferred payment, and (ii) a deposit account. B. Covered Account means (i) an 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 and (ii) any other account that the creditor offers to maintain for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the creditor from identity theft, including financial, operational, compliance, reputation, or litigation risks. C. Identity Theft means a fraud committed or attempted using the identifying information of another person without authority. D. Red Flag means a pattern, practice, or specific activity that indicates the possible existence of identity theft. E. Service Provider means a person that provides a service directly to the financial institution or creditor. IV. Covered Accounts Maintained by the University of Michigan A. External Loan Programs B. Internal Loan Programs C. Student Accounts Page 2 of 6
3 D. Other accounts that may be identified by units as meeting the definition of Covered Account. V. Identification of Red Flags In identifying below specific Red Flags unique to these covered accounts and the applicable business procedures of the University, the University considered the following risk factors: the types of covered accounts offered and maintained, the methods provided for opening and accessing each of those accounts, prior experiences with Identity Theft, and the size, complexity, nature and scope of our institution and its activities. Each of the Red Flags mentioned below may only be applicable to certain of the covered accounts administered by the University. 1. Receipt of a notice of address discrepancy from a credit reporting agency; 2. Documents presented in an application or for the purpose of personal identification are incomplete or appear to have been altered, forged or inauthentic; or are inconsistent with the appearance of the individual presenting the document; or are inconsistent with readily accessible information on file with the University; 3. Challenge questions, used by University to allow students and individuals to access their covered accounts, are answered incorrectly; and 4. The University is notified of special problems in connection with a student s or individual s covered account such as unauthorized charges or transactions, lost or stolen University identification documents, a fraud alert or the account holder is a victim of identity theft. 5. Other red flag indicators that may be identified by the units for their specific covered accounts. Page 3 of 6
4 VI. Red Flag Response After detection of a Red Flag identified above, the following actions will be taken by the University departments that maintain covered accounts under this program, when appropriate given the particular covered account at issue and under the particular circumstances, to confirm the identity of students and individuals when they open and/or access their covered accounts: A. Obtain appropriate personal identifying information (e.g., photo identification, date of birth, academic status, user name and password, address, etc.) from the student or individual account holder, prior to issuing a new or replacement ID card, opening a covered account, or allowing access to a covered account. B. Provide notification when certain changes to a covered account are made online, to students and individuals holding covered accounts to confirm the change was valid and to provide instruction in the event the change is invalid. C. Verify suspicious changes made to covered accounts that relate to an account holder s identity, administration of the account, and billing and payment information. D. Notify appropriate University personnel accessing records related to the affected account holder that a Red Flag has been detected. VII. Prevention and Mitigation of Identity Theft In addition to the efforts noted above to detect Identity Theft, University personnel involved in the administration of the covered accounts will take the following steps, where appropriate and based upon the particular circumstances, to prevent and mitigate occurrences of Identity Theft when a Red Flag is detected: A. Monitor a covered account for evidence of Identity Theft; B. Contact student(s) and/or individual account holder(s); C. Request additional documentation from the student and/or individual account holder to verify identity; D. Change passwords, security codes and other security devices permitting access to the covered account; E. Reopen a covered account with a new account number; Page 4 of 6
5 F. Decline to open a new covered account; G. Close an existing covered account; H. Notify law enforcement; I. Determine that no response is warranted under the particular circumstances; J. Attempt to identify the cause and source of the Red Flag; and K. Take appropriate steps to modify the applicable process to prevent similar activity in the future. L. Notify appropriate University personnel accessing records related to the affected account holder that a Red Flag has been detected. VIII. Program Administration A. Administration and Oversight: Authority to implement and administer the Program and to approve future revisions to the Program shall be delegated to the Chief Financial Officer and the Associate Vice President for Finance. B. Staff Training: University departments that maintain covered accounts should develop and implement plans to effectively train their staff in the identification, detection, prevention and mitigation of the Red Flags identified above that are unique to their specific covered accounts. Staff training should be conducted on a regular basis and as necessary under the circumstances related to the administration of the particular covered account. C. Oversight of service providers: If and when the University engages a service provider to perform an activity in connection with a covered account, University departments that maintain covered accounts under this program should take steps necessary to ensure that the activity of the service provider is conducted in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft. D. Reporting: At least annually, University departments that maintain covered accounts under this program should report to the Office of the Page 5 of 6
6 CFO, regarding their compliance with this Program. The reporting should address the following elements: The department s identification of covered accounts is accurate and up to date, and the department has developed local policies and procedures for addressing the Red Flags associated with the related covered accounts. The department has conducted the appropriate training for their staff as necessary and has taken the appropriate steps to ensure any service provider activity is conducted appropriately. The department has reported significant Red Flag occurrences as appropriate. Suggested program updates or changes as applicable to the Department. E. Program Assessment and Update: The Finance, Audit and Investment Committee will periodically review and if necessary update the Program following a risk assessment of the following factors: prior experiences with identity theft; changes in the methods of identity theft; changes in the method of detection, prevention and mitigation of identity theft; the covered accounts offered and administered by the University; and the potential Red Flags that may arise with respect to the Covered Accounts. This periodic assessment should consider any changes in risks to students and individual account holders of identity theft, findings from the annual departmental reports, and the safety and soundness of the University s identify protection systems. ### To report a suspected incident of identity theft, or if you have questions regarding the University s Identity Theft Protection Program please call Page 6 of 6
Identity Theft Prevention Program. Approved by the Arizona Board of Regents on May 1, 2009
Identity Theft Prevention Program Approved by the Arizona Board of Regents on May 1, 2009 I. Purpose & Scope This Program was developed pursuant to the Federal Trade Commission s ( FTC ) Red Flag Rules
University of Nebraska - Lincoln Identity Theft Prevention Program
I. Purpose & Scope This program was developed pursuant to the Federal Trade Commission s (FTC) Red Flag Rules promulgated pursuant to the Fair and Accurate Credit Transactions Act (the FACT Act). The University
NEVADA SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 13 IDENTITY THEFT PREVENTION PROGRAM (RED FLAG RULES)
NEVADA SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 13 IDENTITY THEFT PREVENTION PROGRAM (RED FLAG RULES) Section 1. NSHE... 2 Section 2. UNR... 4 Section 3. WNC... 9 Chapter 13,
UNIVERSITY OF MASSACHUSETTS IDENTITY THEFT PREVENTION PROGRAM
Doc. T08-109 Passed by the BoT 12/11/08 UNIVERSITY OF MASSACHUSETTS IDENTITY THEFT PREVENTION PROGRAM The Board recognizes that some activities of the University are subject to the provisions of the Fair
Oklahoma State University Policy and Procedures. Red Flags Rules and Identity Theft Prevention
Oklahoma State University Policy and Procedures Rules and Identity Theft Prevention 3-0540 ADMINISTRATION & FINANCE July 2009 Introduction 1.01 Oklahoma State University developed this Identity Theft Prevention
IDENTITY THEFT DETECTION POLICY
IDENTITY THEFT DETECTION POLICY Approved By: President s Cabinet Date of Last Revision: May 5, 2009 Responsible Office/Department: Business and Finance Policy Statement Grand Valley State University (GVSU)
Wake Forest University. Identity Theft Prevention Program. Effective May 1, 2009
Wake Forest University Identity Theft Prevention Program Effective May 1, 2009 I. GENERAL It is the policy of Wake Forest University ( University ) to comply with the Federal Trade Commission's ( FTC )
Identity Theft Prevention Program Derived from the FTC Red Flags Rule requirements
Identity Theft Prevention Program Derived from the FTC Red Flags Rule requirements 1.0 Introduction In 2003, Congress enacted the Fair and Accurate Credit Transactions Act of 2003, 15 U.S.C. Section 1681,
Delta Township Compiled Policy Manual
Delta Township Compiled Policy Manual Title: Delta Township Identity Theft Policy Adoption Date: October 20, 2008 Revision Date: General Purpose: To establish an Identity Theft Prevention Program designed
Policy: 208 Subject: Identity Theft Prevention Program Approved for Board Action: December 22, 2009 Dates Amended:
Policy: 208 Subject: Identity Theft Prevention Program Approved for Board Action: December 22, 2009 Dates Amended: I. PROGRAM ADOPTION Hawkeye REC ("REC") developed this Identity Theft Prevention Program
IDENTITY THEFT PREVENTION PROGRAM
IDENTITY THEFT PREVENTION PROGRAM Concordia Board of Regents May 2009 A Resolution Adopting the Identity Theft Prevention Program WHEREAS, The Federal Trade Commission, under Part 681 of Title 16 in the
CITY OF MARQUETTE, MICHIGAN CITY COMMISSION POLICY
CITY OF MARQUETTE, MICHIGAN CITY COMMISSION POLICY Policy Number: 2008-02 Date Adopted: October 27, 2008 Department: Administrative SUBJECT: IDENTITY THEFT PREVENTION PROGRAM I. OBJECTIVE: A. To protect
Identity Theft Prevention Program
Smyth County Policy Identity Theft Prevention Program Purpose The purpose of the program is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity theft in
Identity Theft Prevention Program
Identity Theft Prevention Program I. PROGRAM PURPOSE AND DEFINITIONS The purpose of this Identity Theft Prevention Program ( Program ) is to detect, prevent and mitigate identity theft in connection with
The Florida A&M University. Identity Theft Prevention Program. Effective May 1, 2009
The Florida A&M University Identity Theft Prevention Program Effective May 1, 2009 I. PROGRAM ADOPTION This Identity Theft Prevention Program ("Program") is established pursuant to the Federal Trade Commission's
Oregon University System Identity Theft Prevention Program Effective May 1, 2009
Oregon University System Identity Theft Prevention Program Effective May 1, 2009 Page 2 I. PROGRAM ADOPTION The Oregon University System ( System ) developed this Identity Theft Prevention Program ("Program")
University of St. Thomas. Identity Theft Prevention Program. (Red Flags Regulation Response)
University of St. Thomas Identity Theft Prevention Program (Red Flags Regulation Response) Revised: January 10, 2013 Program Adoption and Administration The University of St. Thomas ( University ) established
Facts About FACTA Red Flag Identity Theft Prevention Program
FACTA Red Flag Identity Theft Prevention Program FACTA Red Flag Policy Program, page 1 of 6 Contents Overview 3 Definition of Terms 3 Covered Accounts..3 List of Red Flags 3 Suspicious Documents...4 Suspicious
University of Arkansas at Monticello Identity Theft Prevention Program
University of Arkansas at Monticello Identity Theft Prevention Program Overview The University Of Arkansas System Board Of Trustees adopted an Identity Theft Prevention Program (ITP) in compliance with
Approved by the Audit Committee of the Board of Trustees, effective February 3, 2009.
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
ORDINANCE NUMBER 644 AN ORDINANCE ESTABLISHING THE TOWN OF YORKTOWN IDENTITY THEFT PREVENTION PROGRAM
ORDINANCE NUMBER 644 AN ORDINANCE ESTABLISHING THE TOWN OF YORKTOWN IDENTITY THEFT PREVENTION PROGRAM WHEREAS, the Federal Trade Commission, through 16 C.F.R. Part 681.1, adopted Identity Theft Rules requiring
ADRIAN COLLEGE IDENTITY THEFT POLICY
ADRIAN COLLEGE IDENTITY THEFT POLICY Adrian College s Identity Theft Prevention Program I. Program Adoption The Vice President of Business Affairs has developed this Identity Theft Prevention Program (
University Identity Theft and Detection Program (NEW) All Campuses and All Service Providers Subject to the Red Flags Rule
NUMBER: BUSF 4.12 SECTION: SUBJECT: Finance and Planning University Identity Theft and Detection Program (NEW) DATE: March 3, 2011 Policy for: Procedure for: Authorized by: Issued by: All Campuses and
University of Alaska. Identity Theft Prevention Program
University of Alaska Identity Theft Prevention Program Effective beginning October 31, 2009 I. PROGRAM ADOPTION The University of Alaska ( University ) developed this Identity Theft Prevention Program
Green University. Identity Theft Prevention Program. Effective beginning October 31, 2008
Green University Identity Theft Prevention Program Effective beginning October 31, 2008 1 I. PROGRAM ADOPTION Green University ( University ) developed this Identity Theft Prevention Program ("Program")
Christopher Newport University Policy and Procedures
Policy: Red Flag Identity Theft Identification and Prevention Program Policy Number: 3030 Date of Current Revision: Executive Oversight: Executive Vice President Contact Office: Comptroller s Office Policy:
Identity theft. A fraud committed or attempted using the identifying information of another person without authority.
SUBJECT: Effective Date: Policy Number: Identity Theft Prevention 08-24-11 2-105.1 Supersedes: Page Of 2-105 1 8 Responsible Authority: Vice President and General Counsel DATE OF INITIAL ADOPTION AND EFFECTIVE
UNIVERSITY OF RICHMOND IDENTITY THEFT PREVENTION PROGRAM
UNIVERSITY OF RICHMOND IDENTITY THEFT PREVENTION PROGRAM I. Program Adoption. After consideration of the size and complexity of the University s operations and account systems, and the nature and scope
Identity Theft Prevention Program
-- Sample Policy -- Identity Theft Prevention Program Purpose To establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity theft in connection with the opening of
Identification of Red Flags, Detecting Red Flags, and Preventing and Mitigating Identity Theft
George Mason University Identity Theft Prevention Program - Procedures Revised September 30, 2012 Identification of, ing, and Preventing and Mitigating Identity Theft IDENTIFICATION OF COVERED ACCOUNT
identity Theft Prevention and Identification Requirements For Utility
[Utility Name] Identity Theft Prevention Program Effective beginning, 2008 I. PROGRAM ADOPTION The [Utility Name] ("Utility") developed this Identity Theft Prevention Program ("Program") pursuant to the
Texas A&M University Commerce. Identity Theft Prevention Program Effective beginning May 1, 2009
Texas A&M University Commerce Identity Theft Prevention Program Effective beginning May 1, 2009 1 I. PROGRAM ADOPTION Texas A&M University - Commerce ( University ) developed this Identity Theft Prevention
City of Caro Identity Theft Prevention Policy
City of Caro Identity Theft Prevention Policy Purpose The purpose of this policy is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity theft in connection
Florida Agricultural & Mechanical University Board of Trustees Policy
Florida Agricultural & Mechanical University Board of Trustees Policy Board of Trustees Policy Number: Date of Adoption: May 4, 2009 Date of Revision: June 6, 2013 Identity Theft Prevention Policy Subject
Identity Theft Prevention Program Red Flag Rules Policy P093.00 Issued: May 2009
Identity Theft Prevention Program Red Flag Rules Policy P093.00 Issued: May 2009 The Federal Trade Commission has issued a final rule (the Red Flag Rule) under the Fair and Accurate Credit Transactions
Ouachita Baptist University. Identity Theft Policy and Program
Ouachita Baptist University Identity Theft Policy and Program Under the Federal Trade Commission s Red Flags Rule, Ouachita Baptist University is required to establish an Identity Theft Prevention Program
01.230 IDENTITY THEFT PREVENTION PROGRAM (RED FLAGS)
01.230 IDENTITY THEFT PREVENTION PROGRAM (RED FLAGS) Authority: Board of Trustees History: Effective May 1, 2009 (approved initially April 24, 2009) Source of Authority: Related Links: Responsible Office:
University of Dayton Red Flag ID Theft Prevention Program
University of Dayton Red Flag ID Theft Prevention Program I. Program Adoption The University of Dayton developed this Identity Theft Prevention Program ("Program") pursuant to the Federal Trade Commission's
3344-19-01 Identity theft prevention program and red flag compliance policy.
3344-19-01 Identity theft prevention program and red flag compliance policy. (A) Program adoption Cleveland state university has developed this identity theft prevention program ( program ) pursuant to
CHAPTER 101: IDENTITY THEFT PREVENTION PROGRAM
CHAPTER 101: IDENTITY THEFT PREVENTION PROGRAM Section 101.01 Purpose 101.02 Definitions 101.03 Program established 101.04 Administration of program 101.05 Identification of relevant red flags 101.06 Detection
Identity Theft Prevention Program
Identity Theft Prevention Program DATE: 10/22/2015 VERSION 2015-1.0 Abstract Purpose of this document is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity
Florida International University. Identity Theft Prevention Program. Effective beginning August 1, 2009
Florida International University Identity Theft Prevention Program Effective beginning August 1, 2009 I. PROGRAM ADOPTION Florida International University developed this Identity Theft Prevention Program
21.01.04.Z1.01 Guideline: Identity Theft Prevention Program
Texas A&M Health Science Center Guidelines 21.01.04.Z1.01 Guideline: Identity Theft Prevention Program Approved October 7, 2009 Reviewed February 26, 2015 Supplements System Regulation 21.01.04 Reason
Identity Theft Prevention Program. Effective: November 1, 2009
Identity Theft Prevention Program Effective: November 1, 2009 I. BACKGROUND Galveston College ("College" / Institution ) developed this Identity Theft Prevention Program ("Program") pursuant to the Federal
Texas A&M International University Identity Theft Prevention Program
Texas A&M International University Identity Theft Prevention Program 1 I. PROGRAM ADOPTION Texas A&M International University ( University ) developed this Identity Theft Prevention Program ( Program )
TITLE XVIII: IDENTITY THEFT PREVENTION PROGRAM
River Bend Identity Theft Program 1 TITLE XVIII: IDENTITY THEFT PREVENTION PROGRAM Chapter 18.01. IDENTITY THEFT PREVENTION PROGRAM 2 Identity Theft Prevention Program SECTION Chapter 18.01: IDENTITY THEFT
II. F. Identity Theft Prevention
II. F. Identity Theft Prevention Effective Date: May 3, 2012 Revises Previous Effective Date: N/A, New Policy I. POLICY: This Identity Theft Prevention Policy is adopted in compliance with the Federal
UNION COUNTY S IDENTITY THEFT PREVENTION PROGRAM
UNION COUNTY S IDENTITY THEFT PREVENTION PROGRAM This program shall become effective November 1, 2008. Adopted this the 20 th day of October, 2008. I. PREFACE The purpose of this program is to detect,
IDENTITY THEFT PREVENTION PROGRAM
IDENTITY THEFT PREVENTION PROGRAM In compliance with Part 681 of Title 16 of the Code of Federal Regulations implementing Sections 114 of the Fair and Accurate Credit Transactions Act of 2003 ("FACTA"),
Number: 56.300. Index
Identity Theft Prevention Program Section: General Operations Title: Identity Theft Prevention Program Number: 56.300 Index POLICY.100 POLICY STATEMENT.110 POLICY RATIONALE.120 AUTHORITY.130 APPROVAL AND
Pacific University. Policy Governing. Identity Theft Prevention Program. Red Flag Guidelines. Approved June 10, 2009
Pacific University Policy Governing Identity Theft Prevention Program Red Flag Guidelines Approved June 10, 2009 Program adoption Pacific University developed this identity Theft Prevention Program ( Program
University of North Dakota. Identity Theft Prevention Program
University of North Dakota Identity Theft Prevention Program Effective beginning May 1, 2009 I. PROGRAM ADOPTION University of North Dakota ( University ) developed this Identity Theft Prevention Program
VCU Identity Theft Prevention Policy
VCU Identity Theft Prevention Policy POLICY STATEMENT AND PURPOSE Responsible Offices: Office of the Senior Vice President for Finance and Administration Office of the Provost and Vice President for Academic
POLICY: Identity Theft Red Flag Prevention
POLICY SUBJECT: POLICY: Identity Theft Red Flag Prevention It shall be the policy of the Cooperative to take all reasonable steps to identify, detect, and prevent the theft of its members personal information
Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation
Guidelines to FTC Red Flag Rule(reformatted) Appendix A to Part 681 Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation Section 681.2 of this part requires each financial institution
Chatsworth Water Works Commission. Identity Theft Prevention Program. Effective beginning December 1, 2008
Chatsworth Water Works Commission Identity Theft Prevention Program Effective beginning December 1, 2008 I. PROGRAM ADOPTION The Chatsworth Water Works Commission ("Utility") developed this Identity Theft
Village of Brockport Identity Theft Prevention Program Effective December 1, 2009 Confirmed 7/21/14
Village of Brockport Identity Theft Prevention Program Effective December 1, 2009 Confirmed 7/21/14 I. PROGRAM ADOPTION The Village of Brockport ( Village ) developed this Identity Theft Prevention Program
RESOLUTION TO ADOPT IDENTITY THEFT POLICY
RESOLUTION TO ADOPT IDENTITY THEFT POLICY WHEREAS, in late 2008 the Federal Trade Commission (FTC) and federal banking agencies issued a regulation known as the Red Flag Rule under sections 114 and 315
Administrative Procedure 5800 Prevention of Identity Theft in Student Financial Transactions
Reference: Fair and Accurate Credit Transactions Act, ( Pub. L. 108-159) The purpose of the Identity Theft Prevention Program (ITPP) is to control reasonably foreseeable risks to students from identity
Identity Theft Prevention Policy and Procedure
Identity Theft Prevention Policy and Procedure In accordance with the Fair and Accurate Credit Transactions Act of 2003 (FACTA), the college president shall be responsible for developing and maintaining
Identity Theft Prevention Program
The University of North Carolina at Chapel Hill Identity Theft Prevention Program The Board of Trustees of The University of North Carolina at Chapel Hill (the University ) adopts this Identity Theft Prevention
Central Oregon Community College. Identity Theft Prevention Program
Central Oregon Community College Identity Theft Prevention Program Effective beginning May 1, 2009 I. PROGRAM ADOPTION This program has been created to put COCC in compliance with Section 41.90 under the
Northeast Technology Center Board Policy 2110 Page 1 IDENTITY THEFT PREVENTION (MANY COVERED ACCOUNTS)
Page 1 IDENTITY THEFT PREVENTION (MANY COVERED ACCOUNTS) This Policy is adopted to ensure compliance with the Fair and Accurate Credit Transaction Act, 15 U.S.C. 1601 et seq. and the Federal Trade Commission
McLennan Community College
McLennan Community College POLICIES AND PROCEDURES Subject: Identity Theft Prevention Program Reference: E-XXVIII-f Source: Board of Trustees Eff. Date: November 27, 2012 Approval Auth: Board of Trustees
State Of Florida's Real Estate Law
Office of the President University Policy SUBJECT: IDENTITY THEFT PREVENTION PROGRAM Effective Date: 6-17-09 Policy Number: 5.6 Supersedes: Page Of New 1 7 Responsible Authority: Senior Vice President,
policy All terms used in this policy that are defined in 16 C.F.R. 681.2 shall have the same meaning provided in that section.
Name of Policy: Identity theft detection, prevention, and mitigation. Policy Number: 3364-15-12 Approving Officer: President Responsible Agent: Compliance Officer Scope: All University of Toledo Campuses
IDENTITY THEFT PREVENTION PROGRAM TRAINING MODULE February 2009
IDENTITY THEFT PREVENTION PROGRAM TRAINING MODULE February 2009 Table of Contents Introduction to the Training Module.. i I. Introduction. 1 II. Definitions. 3 III. Recognizing Identity Theft.. 6 IV. Identifying
Identity Theft Policy
Identity Theft Policy Policy/Procedure Section 1: Background The risk to Dickinson College (the College ), its employees and students from data loss and identity theft is of significant concern to the
MARSHALL UNIVERSITY BOARD OF GOVERNORS
MARSHALL UNIVERSITY BOARD OF GOVERNORS Policy No. FA-12 IDENTITY THEFT PREVENTION PROGRAM 1 General Information. 1.1 Scope: To identify, detect, and respond appropriately to any Red Flags that are detected
City of Hercules Hercules Municipal Utility Identity Theft Prevention Program
City of Hercules Hercules Municipal Utility Identity Theft Prevention Program Purpose The purpose of the program is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate
IDENTITY THEFT PREVENTION PROGRAM
IDENTITY THEFT PREVENTION PROGRAM I. PROGRAM PURPOSE AND DEFINITIONS A. Purpose The YOSKOVICH FUNERAL HOME ("Funeral Home") developed this Identity Theft Prevention Program ("Program") pursuant to the
CENTENARY COLLEGE POLICIES UNDER THE FAIR & ACCURATE CREDIT TRANSACTION ACT S RED FLAG RULES
(FACTA) April 30, 2009 Approved by: Audit Committee of the Board of Trustees CENTENARY COLLEGE POLICIES UNDER THE A RESOLUTION ADOPTING AN IDENTITY THEFT POLICE Centenary College ( College ) developed
Springfield Technical Community College Identity Theft Prevention Program
Springfield Technical Community College Identity Theft Prevention Program PROGRAM ADOPTION Springfield Technical Community College ( College ) developed this Identity Theft Prevention Program ( Program
COUNCIL POLICY NO. C-13
COUNCIL POLICY NO. C-13 TITLE: POLICY: Identity Theft Prevention Program See attachment. REFERENCE: Salem City Council Finance Committee Report dated November 7, 2011, Agenda Item No. 3 (a) Supplants Administrative
University System of New Hampshire. Identity Theft Prevention Program
University System of New Hampshire Identity Theft Prevention Program Approved by the USNH Board of Trustees on April 30, 2009 I. PROGRAM ADOPTION The University System of New Hampshire (USNH) developed
[Institution or GPLS Name] Red Flag Rules - Identity Theft/Fraud Prevention Program. Effective beginning, 2009
[Institution or GPLS Name] Red Flag Rules - Identity Theft/Fraud Prevention Program Effective beginning, 2009 I. PROGRAM ADOPTION The [Institution or GPLS Name] developed this Identity Theft Prevention
IDENTITY THEFT PREVENTION
IDENTITY THEFT PREVENTION Policy Title: Identity Theft Prevention Program Policy Type: Administrative Policy Number: #41-07 (2014) Approval Date: 05/12/2015 Responsible Office: University Controller Responsible
Identity Theft Prevention Policy
Eastern Kentucky University Policy and Regulation Library 6.#.#P Volume 6, Volume Title: Financial Affairs Chapter #, Chapter Title Section #, Name: Identity Theft Prevention Policy Approval Authority:
NORTHEAST COMMUNITY COLLEGE ADMINISTRATIVE PROCEDURE NUMBER: AP-3250.0 FOR POLICY NUMBER: BP 3250 IDENITY THEFT PREVENTION PROGRAM PROCEDURES
NORTHEAST COMMUNITY COLLEGE ADMINISTRATIVE PROCEDURE NUMBER: AP-3250.0 FOR POLICY NUMBER: BP 3250 IDENITY THEFT PREVENTION PROGRAM PROCEDURES 1. PROCEDURE SUMMARY STATMENT The purpose of this procedure
Ferris State University
Ferris State University BUSINESS POLICY TO: All Members of the University Community 2009:08 DATE: May 2009 I. BACKGROUND IDENTITY THEFT PREVENTION PROGRAM The risk to the University, and its students,
University Policy: Identity Theft Prevention Policy
University Policy: Identity Theft Prevention Policy Policy Category: Ethics, Integrity and Legal Compliance Policies Subject: Detection, prevention and mitigation of identity theft Office Responsible for
THE UNIVERSITY OF NORTH CAROLINA AT GREENSBORO IDENTITY THEFT PREVENTION PROGRAM
Program Adoption THE UNIVERSITY OF NORTH CAROLINA AT GREENSBORO IDENTITY THEFT PREVENTION PROGRAM As a best practice and using as a guide the Federal Trade Commission s ( FTC ) Red Flags Rule, implementing
EXHIBIT A Identity Theft Protection Program. Definitions. For purposes of the Policy, the following definitions apply (1);
EXHIBIT A Identity Theft Protection Program Definitions. For purposes of the Policy, the following definitions apply (1); A. City means: the City of Troy, Montana B. Covered Account means: An account that
Lake Havasu City. Identity Theft Prevention Program
Lake Havasu City Identity Theft Prevention Program Effective beginning May 1, 2009 I. PROGRAM ADOPTION Lake Havasu City (City) developed this Identity Theft Prevention Program (Program) pursuant to the
California State University, Chico. Identity Theft Prevention Red Flags Program
Identity Theft Prevention Red Flags Program Version 1.0 November 16, 2010 REVIEW/APPROVAL HISTORY Document Title: Author: Brooke F. Banks, Information Security Officer Date By Action Pages 10/30/2009 Bill
Appalachian State University Identity Theft Prevention Program Procedures
Appalachian State University Identity Theft Prevention Program Procedures Program Overview I. PURPOSE The purpose of the Program is to: Identify, detect and respond to Red Flags; Prevent and mitigate Identity
Red Flag Rules Information and Training
Red Flag Rules Information and Training What are Red Flag Rules? The Red Flag Rules: - Are enforced by the Federal Trade Commission (FTC), the federal bank regulatory agencies, and the National Credit
Travis County Water Control & Improvement District No. 17. Identity Theft Prevention Program. Effective beginning November 20, 2008
Travis County Water Control & Improvement District No. 17 Identity Theft Prevention Program Effective beginning November 20, 2008 I. PROGRAM ADOPTION The Travis County Water Control and Improvement District
POLICY NO. 449 IDENTITY THEFT PREVENTION POLICY
POLICY NO. 449 IDENTITY THEFT PREVENTION POLICY I. POLICY SUMMARY It shall be the policy of Polk County Rural Public Power District (PCRPPD) to take all reasonable steps to identify, detect, and prevent
David Coble Internal Control Officer
WESTERN WASHINGTON UNIVERSITY S RED FLAGS IDENTITY THEFT PREVENTION PROGRAM IMPLEMENTING SECTIONS 114 AND 315 OF THE FAIR AND ACCURATE CREDIT TRANSACTIONS ACT OF 2003 David Coble Internal Control Officer
ELKHORN RURAL PUBLIC POWER DISTRICT POLICY #1230. Identity Theft Prevention Policy
ELKHORN RURAL PUBLIC POWER DISTRICT 1230-1 I. POLICY SUMMARY POLICY #1230 Identity Theft Prevention Policy It shall be the policy of Elkhorn Rural Public Power District ( District ) to take all reasonable
RANDOLPH COUNTY PUBLIC WORKS. Identity Theft Prevention Program. Adopted September 1, 2009 Effective beginning September 1, 2009
RANDOLPH COUNTY PUBLIC WORKS Identity Theft Prevention Program Adopted September 1, 2009 Effective beginning September 1, 2009 I. PROGRAM ADOPTION The Randolph County Public Works Department ( the Department
CITY OF ANDREWS IDENTITY THEFT PREVENTION PROGRAM
CITY OF ANDREWS IDENTITY THEFT PREVENTION PROGRAM Approved: February 26, 2010 Reviewed: March 18, 2015 I. PROGRAM ADOPTION The City of Andrews ( Utility ) developed this Identity Theft Prevention ( Program
An Overview of the Identity Theft Red Flags and Address Discrepancies under the Fair and Accurate Credit Transactions Act of 2003 Final Rules
An Overview of the Identity Theft Red Flags and Address Discrepancies under the Fair and Accurate Credit Transactions Act of 2003 Final Rules By: Andrea J. Shaw, Esq., Compliance Officer, Gorham Savings
Community College System of New Hampshire Identity Theft Prevention Program Revised 5/4/2009
Community College System of New Hampshire Identity Theft Prevention Program Revised 5/4/2009 Program Adoption The Community College System of New Hampshire ( CCSNH ) developed this Identity Theft Prevention
Identity Theft Policy Created: June 10, 2009 Author: Financial Services and Information Technology Services Version: 1.0
Identity Theft Policy Created: June 10, 2009 Author: Financial Services and Information Technology Services Version: 1.0 Scope: The risk to Loyola University Chicago and its faculty, staff and students
I. Purpose. Definition. a. Identity Theft - a fraud committed or attempted using the identifying information of another person without authority.
Procedure 3.6: Rule (Identity Theft Prevention) Volume 3: Office of Business & Finance Managing Office: Office of Business & Finance Effective Date: December 2, 2014 I. Purpose In 2007, the Federal Trade
RED FLAGS IDENTITY THEFT PREVENTION PROGRAM. Raleigh Radiology Cedarhurst, Wake Forest and Clayton. May 1, 2009
RED FLAGS IDENTITY THEFT PREVENTION PROGRAM Raleigh Radiology Cedarhurst, Wake Forest and Clayton May 1, 2009 The Board of Directors of Raleigh Radiology, LLC and Raleigh Radiology Associates ( the Practice
MOTLOW STATE COMMUNITY COLLEGE
Page 1 of 5 MOTLOW STATE COMMUNITY COLLEGE SUBJECT: FACTA Red Flag Rule and Identity Theft Prevention Program I. BACKGROUND In late 2007 the Federal Trade Commission (FTC) and Federal banking agencies
UNDERSTANDING RED FLAG REGULATIONS AND ENSURING COMPLIANCE. University of Cincinnati Red Flags Rule Protecting Against Identity Fraud
UNDERSTANDING RED FLAG REGULATIONS AND ENSURING COMPLIANCE University of Cincinnati Red Flags Rule Protecting Against Identity Fraud Objectives Background What is the FTC Red Flags Rule? Why do we need