Identity Theft Prevention Program

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Identity Theft Prevention Program"

Transcription

1 Identity Theft Prevention Program Illinois College of Optometry Illinois Eye Institute Effective Date: May 2009 Revised: Review Dates:

2 IDENTITY THEFT PREVENTION POLICY STATEMENT The Illinois College of Optometry (ICO) and Illinois Eye Institute (IEI) have an obligation to comply with the Fair Credit Reporting Act, as amended by the Fair and Accurate Credit Transactions Report Act which includes the requirements set forth by the Interagency Final Rules and Guidelines implementing Sections 114 and 315 of the Act and is governed by the Federal Trade Commission. It is the responsibility of ICO not only to comply with the requirements of the law, but also to be proactive in the prevention of identity theft at ICO/IEI, and to be vigilant in the performance of ICO/IEI's identity theft prevention program. In response to the requirements of this legislation, ICO/IEI has outlined the procedures that will be followed. In order to adequately address this legislation, and due to the different types of transactions performed by ICO and IEI, this policy and procedure statement will provide guidelines as to how ICO/IEI will address the requirements. This Policy supplements and applies in conjunction with ICO/IEI's related policies and programs pertaining to security, student identification, privacy, patient privacy (HIPAA), Information Security, Financial Aid and Business Office or any other relevant policies.

3 KEY COMPONENTS OF THE IDENTITY THEFT PREVENTION PROGRAM Governance Oversight The Board of Trustees Audit Committee or a designated committee of the Board is responsible for reviewing and approving the Identity Theft Prevention ("ITP") Program initially and when the policy is significantly revised. Program Administration The Compliance Office shall be responsible for the oversight the implementation of ICO/IEI s compliance with the requirements. As appropriate, the Compliance Office will provide reports addressing significant regulatory trends, compliance initiatives, and emerging risks to bodies such as the Board of Trustees or Audit Committee and to college/iei departments. Department supervisors are responsible for day-to-day operational implementation of the Identity Theft program. Department supervisors and/or their designees are accountable for the following responsibilities: Establishing and assessing departmental efforts for compliance with the Identity Theft program, detecting and preventing Identity Theft, and reporting of suspicious activity. Conducting testing for compliance with the Identity Theft laws and program and ICO/IEI's internal policies and procedures regarding Identity Theft prevention compliance. Training personnel regarding Identity Theft laws and internal Identity Theft program and procedures. Enforcing Identity Theft prevention requirements when deviations from program or procedure are found. Written Identity Theft Prevention Program ICO/IEI will maintain a written Identity Theft Prevention Program ( ITP ) that is designed to detect, prevent and mitigate identity theft in connection with the opening of a Covered Account or the maintenance of any existing Covered Account. The program will be appropriate based on the size, nature and complexity of ICO/IEI's operations, and shall include reasonable policies and procedures to: Identify relevant indicators ("Red Flags") for the Covered Accounts that ICO/IEI offers or maintains, and incorporate those Red Flags into ICO/IEI's ITP Program; Detect Red Flags that have been incorporated into ICO/IEI's ITP Program; Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity Theft; and Ensure the ITP Program (including the Red Flags determined to be relevant) is updated periodically, to reflect changes in risks to students, patients and employees and to the safety and soundness of ICO/IEI from Identity Theft.

4 Frequency of Policy/Program Review This policy and program will be reviewed no less than annually. The Compliance Office is responsible for determining that the Identity Theft Prevention Policy addresses the most current regulatory requirements and is authorized to propose changes to the Policy. The Compliance Office will update the Identity Theft Prevention Program (including the Red Flags determined to be relevant) periodically, to reflect changes in risks to students, patients and employees or to the safety and soundness of ICO/IEI from Identity Theft, based on factors such as: ICO/IEI's experiences with Identity Theft; Changes in methods of Identity Theft Changes in methods to detect, prevent, and mitigate Identity Theft; Changes in the types of accounts ICO/IEI offers or maintains; and Changes in the business arrangements of ICO/IEI, including mergers, acquisitions, alliances, joint ventures, and service provider arrangements. TRAINING The Compliance Office and department managers are responsible for developing and maintaining the content which will be used to train all employees in areas identified as having risk of exposure to Identity Theft and/or those areas responsible for compliance with this Program. Each area shall be responsible for ensuring that its respective employees receive the required training in the manner and time specified by the Compliance Office. Each area shall also be responsible for ensuring new employees receive the required training and for providing any additional training specific to the respective area as needed. Appropriate training may be conducted via live presentations, Internet training, teleconference, written materials, one on one demonstration or any other reasonable learning vehicle for the material and audience. Records of training must be maintained sufficient to demonstrate the effectiveness of the program.

5 IDENTITY THEFT PREVENTION PROGRAM ELEMENTS Definitions For the purposes of this Program, the following definitions apply: COVERED ACCOUNT: An account that ICO/IEI offers or maintains primarily for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions such as a student account, institutional loans to students, deferment of tuition payments; patient accounts for health care services and any other account that ICO/IEI offers or maintains for which there is a reasonably foreseeable risk to students or to the safety and soundness of ICO/IEI from identity theft, including financial, operational, compliance, reputation or litigation risks. CREDITOR: Any organization who defers payment for services rendered, such as an organization that bills at the end of the month for services rendered the previous month. CLEAR AND CONSPICUOUS: Reasonably understandable and designed to call attention to the nature and significance of the information presented. IDENTITY THEFT: A fraud committed or attempted using the identifying information of another person without authority. IDENTIFYING INFORMATION: Any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including any: Name, social security number, date of birth, official State or government issued driver's license or identification number, alien registration number, government passport number, employer or taxpayer identification number; Unique biometric data, such as fingerprint, voice print, retina or iris image, or other unique physical representation; Unique electronic identification number, address, or routing code; or Telecommunication identifying information or access device. NOTICE OF ADDRESS DISCREPANCY: A notice sent to a user by a consumer reporting agency pursuant that informs the user of a substantial difference between the address for the student that the user provided to request the consumer report and the address(es) in the agency's file for the student. RED FLAG: A pattern, practice, or specific activity that indicates the possible existence of identity theft. SERVICE PROVIDER: A person that provides a service directly to ICO/IEI. Assessment of Identity Theft Risks Risk is the potential that events, expected or unanticipated, may have an adverse impact on a students, patients and employees. Effective identity theft risk management requires an understanding of existing and potential risks that may arise from ICO/IEI operations. The Compliance Office will periodically conduct a risk assessment to determine whether it offers or maintains Covered Accounts, as well as the risk associated with the Covered Accounts offered or maintained by ICO/IEI.

6 Identification of Red Flags ICO/IEI will identify and periodically assess, together with existing policies, procedures and processes to identify and document the Red Flags relevant to its operations. As part of this determination, ICO/IEI will incorporate relevant Red Flags from sources such as: Incidents of Identity Theft that ICO/IEI has experienced; Methods of Identity Theft that ICO/IEI has identified that reflect changes in Identity Theft risks; and Applicable supervisory guidance Relevant resources. The ITP Program includes, as appropriate, Red Flags from the following categories: Alerts, notifications, or other warnings received from consumer reporting agencies or service providers, such as fraud detection services or credit reporting agencies 1. A fraud alert included with a consumer report such as a credit report. 2. Notice of a credit freeze in response to a request for a credit report. 3. A credit reporting agency providing a notice of address discrepancy. 4. Unusual credit activity, such as an increased number of accounts or inquiries The presentation of suspicious documents 5. Identification appearing altered or forged. 6. Photograph on ID inconsistent with appearance or physical description. 7. Information on ID inconsistent with information provided by person opening account. 8. Information on ID, such as signature, inconsistent with information on file. 9. Application appearing forged or altered or destroyed and reassembled The presentation of suspicious personal identifying information 10. Information on ID not matching any address in the consumer report, Social Security number has not been issued or appears on the Social Security Administration s Death Master File, a file of information associated with Social Security numbers of those who are deceased. 11. Lack of correlation between Social Security number range and date of birth. 12. Personal identifying information associated with an account you know to have fraud activity. 13. Suspicious addresses supplied, such as a mail drop or prison, or phone numbers associated with pagers or answering service. 14. Social Security number provided matching that submitted by another person opening an account or other customers. 15. An address or phone number matching that has been used by a large number of people opening accounts. 16. The person opening the account unable to supply identifying information in response to notification that the application is incomplete.

7 17. Personal information inconsistent with information already on file at financial institution or creditor. 18. Person opening account or customer unable to correctly answer challenge questions beyond what information can be found in a wallet or credit report. The unusual use of, or other suspicious activity related to an account 19. Shortly after change of address, receiving request for additional users of account. 20. Most of available credit used for cash advances, jewelry or electronics (items that can easily be converted to cash), plus customer fails to make first payment. 21. Drastic change in payment patterns, use of available credit or spending patterns. 22. An account that has been inactive for a lengthy time suddenly exhibiting unusual activity. 23. Mail sent to customer repeatedly returned as undeliverable despite ongoing transactions on active account. 24. Being notified that customer is not receiving paper account statements. 25. Being notified of unauthorized charges or transactions on an account. Notice from an account holder, victims of Identity Theft, law enforcement authorities, or other persons regarding possible Identity Theft in connection with an account held by ICO/IEI 26. Being notified that it has opened a fraudulent account for a person engaged in identity theft. Prevention and Mitigation of Identity Theft ICO/IEI may maintain many different types of covered accounts in several different departments. These covered accounts included, but are not limited to: Student demographic information such as applications, registration, etc. Student financial accounts for tuition and fees, room and board, bookstore, etc. Perkins Loan accounts Student Emergency Loan accounts ICO One card accounts Health Professions Loan accounts Patient demographic and financial accounts Health care records Employee demographic accounts such as benefit transactions, payroll and health insurance

8 Prevention of identity theft has many mechanisms but some include: Ensuring websites are secure. Complete and secure destruction of paper records Password protected computers. Avoiding the use of Social Security numbers; using only the last four digits Up to date virus protection Identification verification Obtaining the least information necessary Detection of Red Flags ICO/IEI will take appropriate steps to detect Red Flags in connection with the opening of Covered accounts and the maintenance of existing Covered Accounts, such as by: Obtaining identifying information about, and verifying the identity of, a person opening a Covered Account; and Authenticating identification, monitoring transactions, and verifying the validity of change of address requests, in the case of existing Covered Accounts. Response to Red Flags: ICO/IEI will respond appropriately to the Red Flags it has detected commensurate with the degree of risk posed. In determining an appropriate response, management will consider aggravating factors that may heighten the risk of Identity Theft, such as a data security incident that results in unauthorized access to account records held by ICO/IEI or third party, or notice that a student, patient or employee has provided information related to a Covered Account held by ICO/IEI to someone fraudulently claiming to represent ICO/IEI or to a fraudulent website. Appropriate responses may include the following: Monitoring a Covered Account for evidence of Identity Theft; Contacting the account holder; Changing any 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 new Covered Account; Closing an existing Covered Account; Not attempting to collect on a Covered Account or not sending a Covered Account to a debt collector; Notifying law enforcement; and/or Determining that no response is warranted under the particular circumstances. Oversight of Service Provider Arrangements When ICO/IEI engages a Service Provider to perform an activity in connection with one or more Covered Accounts, ICO/IEI will take appropriate steps to ensure that any activities of the service provider are conducted in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of Identity Theft. The oversight of Service Providers shall be performed according to the standards set forth by ICO/IEI's Identity Theft Program, patient information (HIPAA,) Information Security and other relevant policies.

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 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

More information

Identity Theft Prevention Program

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

More information

Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation

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

More information

University Identity Theft and Detection Program (NEW) All Campuses and All Service Providers Subject to the Red Flags Rule

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

More information

Lake Havasu City. Identity Theft Prevention Program

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

More information

CENTENARY COLLEGE POLICIES UNDER THE FAIR & ACCURATE CREDIT TRANSACTION ACT S RED FLAG RULES

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

More information

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

More information

IDENTITY THEFT PREVENTION PROGRAM

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"),

More information

Identity Theft Prevention Program

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

More information

University Policy: Identity Theft Prevention Policy

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

More information

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 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

More information

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.

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

More information

City of Hercules Hercules Municipal Utility Identity Theft Prevention Program

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

More information

Wake Forest University. Identity Theft Prevention Program. Effective May 1, 2009

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 )

More information

COUNTY OF SONOMA AND SONOMA COUNTY COMMUNITY DEVELOPMENT COMMISSION IDENTITY THEFT PREVENTION PROGRAM

COUNTY OF SONOMA AND SONOMA COUNTY COMMUNITY DEVELOPMENT COMMISSION IDENTITY THEFT PREVENTION PROGRAM COUNTY OF SONOMA AND SONOMA COUNTY COMMUNITY DEVELOPMENT COMMISSION IDENTITY THEFT PREVENTION PROGRAM In Accordance with the Fair and Accurate Credit Transactions Act of 2003 And 16 CFR 681.1 and 16 CFR

More information

Central Oregon Community College. Identity Theft Prevention Program

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

More information

CHAPTER 99: IDENTITY THEFT PREVENTION PROGRAM

CHAPTER 99: IDENTITY THEFT PREVENTION PROGRAM CHAPTER 99: IDENTITY THEFT PREVENTION PROGRAM Section 99.01 Objective 99.02 Scope 99.03 Definitions 99.04 Policy 99.05 Program Management and Accountability 99.06 Responsibility 99.07 Identity Theft Prevention

More information

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) 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,

More information

UNIVERSITY OF MASSACHUSETTS IDENTITY THEFT PREVENTION PROGRAM

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

More information

California State University, Fullerton Identity Theft Prevention ( Red Flags Rule ) Implementation Plan

California State University, Fullerton Identity Theft Prevention ( Red Flags Rule ) Implementation Plan Page 1 of 15 California State University, Fullerton Identity Theft Prevention ( Red Flags Rule ) Implementation Plan Page 2 of 15 VERSION CONTROL Document Title: Author: California State University, Fullerton

More information

Administrative Procedure 5800 Prevention of Identity Theft in Student Financial Transactions

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

More information

UNION COUNTY S IDENTITY THEFT PREVENTION PROGRAM

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,

More information

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 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

More information

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

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

More information

Identity Theft Prevention Policy. Effective Date: January 1, 2011. Policy Statement

Identity Theft Prevention Policy. Effective Date: January 1, 2011. Policy Statement Identity Theft Prevention Policy Effective Date: January 1, 2011 Policy Statement Identity Theft is a crime in which an individual wrongfully obtains and uses another person's personal data, usually for

More information

Identity Theft Prevention Program

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

More information

CITY OF MARQUETTE, MICHIGAN CITY COMMISSION POLICY

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

More information

I. Purpose. Definition. a. Identity Theft - a fraud committed or attempted using the identifying information of another person without authority.

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

More information

Weber Human Services Identity Theft Prevention Policy

Weber Human Services Identity Theft Prevention Policy Weber Human Services Identity Theft Prevention Policy Purpose: Weber Human Services (WHS) is committed to protecting the privacy of the Protected Health Information ( PHI ) of our clients and the Personal

More information

University of St. Thomas. Identity Theft Prevention Program. (Red Flags Regulation Response)

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

More information

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: 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

More information

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 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

More information

SOUTH TEXAS COLLEGE. Identity Theft Prevention Program and Guidelines. FTC Red Flags Rule

SOUTH TEXAS COLLEGE. Identity Theft Prevention Program and Guidelines. FTC Red Flags Rule SOUTH TEXAS COLLEGE Identity Theft Prevention Program and Guidelines FTC Red Flags Rule Issued June 24, 2009 Table of Contents Section Section Description Page # 1 Section 1: Program Background and Purpose

More information

University of Arkansas at Monticello Identity Theft Prevention Program

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

More information

[Utility Name] Identity Theft Prevention Program. Effective beginning, 2008

[Utility Name] Identity Theft Prevention Program. Effective beginning, 2008 [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

More information

University of Nebraska - Lincoln Identity Theft Prevention Program

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

More information

UNIVERSITY OF CALIFORNIA, MERCED Red Flag and Security Incident Reporting Policy

UNIVERSITY OF CALIFORNIA, MERCED Red Flag and Security Incident Reporting Policy UNIVERSITY OF CALIFORNIA, MERCED Red Flag and Security Incident Reporting Policy RESPONSIBLE OFFICIAL : Executive Vice Chancellor/Provost RESPONSIBLE OFFICIAL : Business & Financial Services EFFECTIVE

More information

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 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

More information

Identity Theft Prevention Program. Effective beginning April 14, 2010

Identity Theft Prevention Program. Effective beginning April 14, 2010 Identity Theft Prevention Program Effective beginning April 14, 2010 PROGRAM ADOPTION Cobalt Financial Corporation ( Broker ) developed this Identity Theft Program ( Program ) pursuant to the Federal Trade

More information

TITLE XVIII: IDENTITY THEFT PREVENTION 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

More information

DOYLESTOWN FAMILY MEDICINE, P.C. IDENTITY THEFT PREVENTION PROGRAM TEMPLATE ADOPTED AND EFFECTIVE: APRIL 15, 2009 UPDATED:

DOYLESTOWN FAMILY MEDICINE, P.C. IDENTITY THEFT PREVENTION PROGRAM TEMPLATE ADOPTED AND EFFECTIVE: APRIL 15, 2009 UPDATED: DOYLESTOWN FAMILY MEDICINE, P.C. IDENTITY THEFT PREVENTION PROGRAM TEMPLATE ADOPTED AND EFFECTIVE: APRIL 15, 2009 UPDATED: I. Adoption of Identity Theft Prevention Program Doylestown Family Medicine, P.C.

More information

Detecting, Preventing, and Mitigating Identity Theft

Detecting, Preventing, and Mitigating Identity Theft THE RED FLAGS RULE Detecting, Preventing, and Mitigating Identity Theft Training for Ball State University s Identity Theft Protection Program What is the Red Flag Rule? Congress passed the Fair and Accurate

More information

Identity Theft Prevention Program Derived from the FTC Red Flags Rule requirements

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,

More information

Delta Township Compiled Policy Manual

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

More information

Identity theft. A fraud committed or attempted using the identifying information of another person without authority.

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

More information

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 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

More information

UCLA Policy 313: Prevention of Identity Theft

UCLA Policy 313: Prevention of Identity Theft UCLA Policy 313: Prevention of Identity Theft Issuing Officer: Executive Vice Chancellor and Provost Responsible Dept: Corporate Financial Services Effective Date: July 29, 2009 Supersedes: New I. REFERENCES

More information

IDENTITY THEFT DETECTION POLICY

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)

More information

Identity Theft Prevention Program

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

More information

City of Watauga Utility Billing Department Identity Theft Prevention Program. Effective beginning November 1, 2008

City of Watauga Utility Billing Department Identity Theft Prevention Program. Effective beginning November 1, 2008 City of Watauga Utility Billing Department Identity Theft Prevention Program Effective beginning November 1, 2008 A. PROGRAM ADOPTION The City of Watauga Utility Billing Department ("Utility") developed

More information

Appalachian State University Identity Theft Prevention Program Procedures

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

More information

Policy No: TITLE: EFFECTIVE DATE: CANCELLATION: REVIEW DATE:

Policy No: TITLE: EFFECTIVE DATE: CANCELLATION: REVIEW DATE: Policy No: TITLE: AP-OP-07.2 Identity Theft Prevention Program EFFECTIVE DATE: April 11, 2014 ADMINISTERED BY: Office of the President CANCELLATION: REVIEW DATE: Fall 2016 PURPOSE To establish an Identity

More information

RESOLUTION NO. 2009-1

RESOLUTION NO. 2009-1 RESOLUTION NO. 2009-1 A RESOLUTION OF THE MAYOR AND COUNCI8L OF THE CITY OF ST. ANTHONY, IDAHO, ADOPTING AN IDENTY THEFT PREVENTION PROGRAM WHEREAS, Section 114 of the Fair and Accurate Transaction Act

More information

Number: 0-109 Identity Theft Program Procedures and Protocol Responsible Office: Business and Finance

Number: 0-109 Identity Theft Program Procedures and Protocol Responsible Office: Business and Finance POLICY USF System USF USFSP USFSM Number: 0-109 Subject: Identity Theft Program Procedures and Protocol Responsible Office: Business and Finance Date of Origin: 1-11-11 Date Last Amended: Date Last Reviewed:

More information

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 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

More information

TOWN OF APPLE VALLEY, CALIFORNIA AGENDA MATTER

TOWN OF APPLE VALLEY, CALIFORNIA AGENDA MATTER TOWN OF APPLE VALLEY, CALIFORNIA AGENDA MATTER Subject Item: RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF APPLE VALLEY, CALIFORNIA ADOPTING AN IDENTITY THEFT PREVENTION PROGRAM SUMMARY STATEMENT In 2003,

More information

IDENTITY THEFT PREVENTION PROGRAM

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

More information

Oklahoma State University Policy and Procedures. Red Flags Rules and Identity Theft Prevention

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

More information

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); 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

More information

RANDOLPH COUNTY EMERGENCY SERVICES & TAX DEPARTMENT. Identity Theft Prevention Program. Adopted August 3, 2009 Effective beginning August 1, 2009

RANDOLPH COUNTY EMERGENCY SERVICES & TAX DEPARTMENT. Identity Theft Prevention Program. Adopted August 3, 2009 Effective beginning August 1, 2009 RANDOLPH COUNTY EMERGENCY SERVICES & TAX DEPARTMENT Identity Theft Prevention Program Adopted August 3, 2009 Effective beginning August 1, 2009 I. PROGRAM ADOPTION The Randolph County Emergency Services

More information

Florida Agricultural & Mechanical University Board of Trustees Policy

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

More information

City of Caro Identity Theft Prevention Policy

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

More information

IDENTITY THEFT PREVENTION PROGRAM

IDENTITY THEFT PREVENTION PROGRAM IDENTITY THEFT PREVENTION PROGRAM 1. BACKGROUND The University of Tennessee (UT) developed this Identity Theft Prevention Program pursuant to the Federal Trade Commission s Red Flags Rule, Section 114

More information

The National Association of Community Health Centers, Inc. ISSUE BRIEF

The National Association of Community Health Centers, Inc. ISSUE BRIEF The National Association of Community Health Centers, Inc. ISSUE BRIEF FTC Red Flag Rule Considerations in Developing an Identity Theft Prevention Program April 2009 Prepared for NACHC by: Carrie Bill

More information

ELKHORN RURAL PUBLIC POWER DISTRICT POLICY #1230. Identity Theft Prevention Policy

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

More information

Green University. Identity Theft Prevention Program. Effective beginning October 31, 2008

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")

More information

University of Dayton Red Flag ID Theft Prevention Program

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

More information

Oregon University System Identity Theft Prevention Program Effective May 1, 2009

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")

More information

DMACC IDENTITY THEFT- RED FLAGS PROCEDURES

DMACC IDENTITY THEFT- RED FLAGS PROCEDURES DMACC IDENTITY THEFT- RED FLAGS PROCEDURES This document contains identity theft red flag procedures for Des Moines Area Community College. Section Topic Page 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 XX PURPOSE

More information

Florida International University. Identity Theft Prevention Program. Effective beginning August 1, 2009

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

More information

University of Alaska. Identity Theft Prevention Program

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

More information

[FACILITY NAME] IDENTITY THEFT PREVENTION PROGRAM. Effective May 1, 2009

[FACILITY NAME] IDENTITY THEFT PREVENTION PROGRAM. Effective May 1, 2009 [FACILITY NAME] IDENTITY THEFT PREVENTION PROGRAM Effective May 1, 2009 Because [FACILITY NAME] offers and maintains covered accounts, as defined by 16 C.F.R. Part 681 (the Regulations ), [FACILITY NAME]

More information

California State University, Chico. Identity Theft Prevention Red Flags Program

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

More information

Springfield Technical Community College Identity Theft Prevention Program

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

More information

Identity Theft Prevention Policy and Procedure

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

More information

Identity Theft Prevention Program

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

More information

RANDOLPH COUNTY HEALTH DEPARTMENT. Identity Theft Prevention Program. Adopted August 3, 2009 Effective beginning August 1, 2009

RANDOLPH COUNTY HEALTH DEPARTMENT. Identity Theft Prevention Program. Adopted August 3, 2009 Effective beginning August 1, 2009 RANDOLPH COUNTY HEALTH DEPARTMENT Identity Theft Prevention Program Adopted August 3, 2009 Effective beginning August 1, 2009 I. PROGRAM ADOPTION The Randolph County Health Department ( the Department

More information

UNC Asheville. Red Flag Rule and NC Identity Protection Act Information

UNC Asheville. Red Flag Rule and NC Identity Protection Act Information UNC Asheville Red Flag Rule and NC Identity Protection Act Information Why Should UNC Asheville be Concerned? The Federal Trade Commission (FTC) regulates financial transactions at UNC Asheville The FTC

More information

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 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

More information

Identity Theft Prevention Policy

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:

More information

21.01.04.Z1.01 Guideline: 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

More information

RESOLUTION TO ADOPT IDENTITY THEFT POLICY

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

More information

Spotting ID Theft Red Flags A Guide for FACTA Compliance. An IDology, Inc. Whitepaper

Spotting ID Theft Red Flags A Guide for FACTA Compliance. An IDology, Inc. Whitepaper Spotting ID Theft Red Flags A Guide for FACTA Compliance An IDology, Inc. Whitepaper With a November 1 st deadline looming for financial companies and creditors to comply with Sections 114 and 315 of the

More information

Board of Commissioners Policy. Town of Nags Head Identity Theft Protection Program. Adopted October 22, 2008

Board of Commissioners Policy. Town of Nags Head Identity Theft Protection Program. Adopted October 22, 2008 M. Renée Cahoon Mayor Anna D. Sadler Mayor Pro Tem Charlie Cameron Town Manager/ Public Safety Director Town of Nags Head Post Office Box 99 Nags Head, North Carolina 27959 Telephone 252-441-5508 Fax 252-441-0776

More information

ACCG Identity Theft Prevention Program. ACCG 50 Hurt Plaza, Suite 1000 Atlanta, Georgia 30303 (404)522-5022 (404)525-2477 www.accg.

ACCG Identity Theft Prevention Program. ACCG 50 Hurt Plaza, Suite 1000 Atlanta, Georgia 30303 (404)522-5022 (404)525-2477 www.accg. ACCG Identity Theft Prevention Program ACCG 50 Hurt Plaza, Suite 1000 Atlanta, Georgia 30303 (404)522-5022 (404)525-2477 www.accg.org July 2009 Contents Summary of ACCG Identity Theft Prevention Program...

More information

II. F. Identity Theft Prevention

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

More information

[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 [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

More information

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 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

More information

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 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

More information

Number of Pages: 5 Number of Forms: 0 Saved As: X:/Policies & Procedures/13. JCAHO STD s (if applicable): N/A

Number of Pages: 5 Number of Forms: 0 Saved As: X:/Policies & Procedures/13. JCAHO STD s (if applicable): N/A 15.05 Identity Theft Prevention Program Policy: Identity Theft Prevention Program Effective Date: Manual: RFHC Clinical Policies and Procedures Revision Date: Number of Pages: 5 Number of Forms: 0 Saved

More information

POLICY: Identity Theft Red Flag Prevention

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

More information

Identity Theft Policy

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

More information

Number: 56.300. Index

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

More information

University of North Dakota. Identity Theft Prevention 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

More information

MARSHALL UNIVERSITY BOARD OF GOVERNORS

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

More information

COUNCIL POLICY STATEMENT

COUNCIL POLICY STATEMENT COUNCIL POLICY STATEMENT Policy No. 44 General Subject: Finance Specific Subject: Identity Theft Policy and Prevention Program Date Approved: October 20, 2008 The following policy is to implement the requirements

More information

Wholesale Broker Red Flag/Identity Theft Prevention Program Certification

Wholesale Broker Red Flag/Identity Theft Prevention Program Certification Wholesale Broker Red Flag/Identity Theft Prevention Program Certification Federal regulations require that all financial institutions and their affiliates create an identity theft prevention program in

More information

Texas A&M International University Identity Theft Prevention Program

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 )

More information

Ouachita Baptist University. Identity Theft Policy and Program

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

More information

THE UNIVERSITY OF NORTH CAROLINA AT GREENSBORO IDENTITY THEFT PREVENTION PROGRAM

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

More information