Red Flag Rules: A Step by Step Guide to Developing a Prevention & Training Program

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1 Red Flag Rules: A Step by Step Guide to Developing a Prevention & Training Program A Case Study of Sam Houston State University s Red Flag Program Dr. Kristy L. Vienne

2 Objective Participants will: Understand Red Flag Rules Learn how to effectively: Design a Red Flag Program Implement a Red Flag Program Train Employees on their Campus Red Flag Program Review Case Study of Sam Houston State University

3 Red Flags Rules Defined A RED FLAG is defined as a pattern, practice or specific activity involving a university community member (faculty, staff, or student) that indicates the possible existence of identity theft Purpose of program is to help identify the warning signs or RED FLAG of identity theft in the day-to-day operations of a university and campus operations Enables financial institutions to detect and defend its students against fraud and identity theft

4 Red Flag Rules Red Flag Rule requires creditors (i.e. SHSU) to offer/maintain covered accounts to adopt a written identity theft prevention program and train its employees how to: Detect warning signs of identity theft in day to day campus operations Take Steps to Prevent identity theft on campus Mitigate any damage or liability to the students

5 Covered Accounts on Campus Student Accounts Student Loans Deferment of Tuition Payments Emergency Loans University Health Center Patients Bearkat OneCard

6 Implementing a Red Flag Program Develop a Red Flag Oversight Team VP For Finance Director of Admissions Director of Financial Aid Bursar Registrar Director/Manager of Card Program Chief of Campus Security Information Resources/IT

7 Program Oversight Program Coordinators in the respective areas should: Maintain a log of incidents in their area Immediately report incidents to the Program Administrator for further investigation Show responsible for ensuring availability and compliance of departmental training Provide, on a semi-annual basis, the Program Administrator with suggested Red Flag Program updates to reflect changes in risk assessment to students Program Administrator will: Forward any necessary case to UPD for investigation Recommend to or approve information resources to issue a new Sam ID or computer user ID for a student, when warranted Report any warranted cases to third party agencies Recommend additional training as warranted

8 Oversight of 3 rd Party Service Providers Require as part of the contract that these providers have policies, procedures and programs that comply with the Red Flag Rule. Higher One Sam Houston State University does not have access to or authority over the banking accounts contracted through the Bearkat OneCard. All banking transactions are handled by Higher One and their designees. Higher Ones privacy statement and Red Flag Policy can be found in Appendix X & X respectively.

9 Red Flag Rules Program Written document Official University Red Flags Policy Training Program Presentation Materials Certificates Working Plan/Responses to: Detecting Red Flags Preventing Red Flags Mitigating Red Flags Yearly Review

10 Red Flag Policy This document should serve as the direction of the entire Red Flag Program Developed by Key Stake Holders (i.e. oversight team) Identified Program Oversight Team Approved by Cabinet Support of Upper Administrators

11 Red Flag Policy Background to Red Flags Purpose & Scope Red Flag Rule Definitions Identifying & Detecting of Red Flags Campus Responses to Red Flag Detections Detail of Training Program Oversight of Third Party Service Providers Annual Review/Periodic Update Red Flag Rules Program Administration Red Flag Reporting

12 Sample Red Flag Policy

13 Categories of Red Flags Alerts, notifications, or warnings from Consumer Reporting Agency Presentation of suspicious documents Presentation of suspicious personal identifying information Suspicious account activity Notice from External/Other Sources

14 Notifications of Red Flags Internal Notification Any department employee who becomes aware of a suspected or actual fraudulent use of a customer s identity must notify their respective Red Flag Rules Program Coordinator. The Program Coordinator should complete an incident form, noting action taken by the respective office and keeping an internal file on the instance. The incident form should be forwarded to relevant university departments Other university officials may be notified as needed including but not limited to: Director of Housing, Bursar s Office, Student Judicial Affairs, Financial Aid, and Director of Payroll Services.

15 Notifications of Red Flags External Notifications If the University is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it (i.e., the University) has opened a fraudulent account for a person engaged in identity theft, the administrator MUST ACT immediately in order to protect the student and the University from the possible effects of identity theft. In cases of external notification, the Program Administrator, or their designee, will be responsible for: Notifying the affected individual(s) of the report that was received Must inform the individual of the action the university has undertaken to protect the student s university identification cards and/or covered account activity.

16 Responses to Red Flags After receiving a report, possible responses include: 1. Canceling any transaction(s) in question. 2. Not opening a new account or closing the account in question. 3. If there is a determination of probable or actual identity theft, the Office of Information Security will be contacted and Campus Safety will be notified for a full investigation of criminal wrongdoing. 4. Notifying of other campus administrators as necessary for a quick and immediate mitigation of fraud activity. 5. Re-opening a covered account with a new account number for the victim (e.g., student) in question.

17 Responses to Red Flags 6. Changing any passwords or other security protocols that would permit access to the covered accounts, system database, or other student records in question 7. Continuing to monitor the covered account or database for evidence of identity theft. 8. Notify the actual student that fraud has been attempted or that it has occurred. 9. If applicable, not attempting to collect on a covered account or not selling a covered account under question to a credit collection agency.

18 Incident Report In all situations where it is determined a Red Flag has been identified, the Program Administrator, or their designee, will be responsible for: a) documenting the occurrence; b) describing its review of the matter; c) listing any specific actions taken to mitigate the impact of the effects of the actual or potential identify theft discovered. Report should also include a description of any additional actions that the Program Administrator believes are systemically necessary for the campus Updating policy & procedures Mitigate the likelihood of a reoccurrence of this Red Flag in the future.

19 Method of Contact to Affected Student , if the address is in the department/university records. By telephone, provided the contact is made directly with the affected person and appropriately documented. Written notice, by Certified Mail, if all other methods fail

20 Possible Corrective Actions to Red Flag Incidents Determining no response is warranted under particular circumstances by Departmental Program Coordinator No evidence of Identity Theft is Determined Placing the covered account on hold from any further access, use, or disclosure until the Red Flag event is fully investigated by authorities Isolating and correcting inaccuracies in student records resulting from identity theft

21 Red Flag Rules Reporting/Yearly Review The Red Flags Program Coordinators will report to the Program Administrator, on an annual designated basis, in writing or by meeting, on compliance with the Red Flag Rule. The report will include any material matters and issues regarding this program, such as: Implementation of the program; Departmental Employee training; Effectiveness of policies and procedures in addressing risk in how accounts are opened and maintained; Service provider (third party) arrangements; Significant incidents involving identity theft and management response; Recommendations for changes

22 Employee Training Program Program should take time to explain the rules to staff, and train them to spot security vulnerabilities. Periodic training should be held to emphasize the importance the university places on meaningful data security practices; A well-trained workforce is the best defense against identity theft and data breaches. Employees should be updated and additional training provided as the university determine additional campus risks and vulnerabilities.

23 Employees who violate security policy should be subjected to discipline, up to, and including, dismissal. Employee Training Program Employees should be alerted to attempts at phishing. Employees should be required to notify their respective Red Flag Program Coordinator immediately if there is a potential security breach (e.g., a lost or stolen university laptop or computer, suspected office break-in)

24 QUESTIONS?

25 Contact Information Dr. Kristy L. Vienne, AFC, CPFC Assistant Vice President for Student Services Sam Houston State University Box 2538 Huntsville, TX (936)

26 Sample Training Program

27 Objective Participants will: Understand what Red Flag Rules are Understand why Red Flags are important on our campus Comply with Red Flag Rules Identify Red Flag Rules Detect Red Flag Rules Prevent and Mitigate Identity Theft On Campus Update the SHSU Red Flag Rules Program Additional Red Flag Rules Resources

28 Red Flags Rules Defined A RED FLAG is defined as a pattern, practice or specific activity involving a university community member (faculty, staff, or student) that indicates the possible existence of identity theft Purpose of this training is to help you better identify the warning signs or RED FLAG of identity theft in the day-to-day operations of a university and campus operations Enables financial institutions to detect and defend its students against fraud and identity theft

29 Definitions Creditor an entity which defers payment for services rendered, such as an organization that bills at the end of the month for services rendered the previous month. Covered Account a customer account that involves multiple payments or transactions. The establishment of a continuing relationship with the institution is also advised. Financial Institution defined as a state or national bank, a state or federal savings and loan association, a mutual savings bank, a state or federal credit union, or any other entity that holds a transaction account belonging to a consumer. Transaction account a deposit or other account from which the owner makes payments or transfers.

30 Covered Accounts Student Accounts Student Loans Deferment of Tuition Payments Emergency Loans University Health Center/Medical Ctr Patients OneCard Office

31 Rules Governing Red Flags Rules Rules are designed to align with mandate issued by the Federal Government Sections 114 and 315 of Fair and Accurate Credit Transactions Act of 2003 FTC, Federal Financial Institution Regulatory Agencies, and National Credit Union adopted these regulations in October 2007 Became known as the Red Flags Rule

32 The Facts In 2008, there were 10 million victims of identity theft in the United States. This presented a 22% increase over (Javelin Strategy and Research, 2009) In the United States, 1 in every 10 consumers has already been victimized by identity theft. (Javelin Strategy and Research, 2009) 38-48% victims discover their identity has been compromised within three months, while 9-18% of victims do not learn that their identity has been stolen for 4 or more years. (Identity Theft Resource Center Aftermath Study, 2004)

33 College Students are the #1 Target 31% of identity theft victims fall between the ages of (Federal Trade Commission) Top 3 Reasons according to Dave Ramsey 1. Naivety 2. Receive many credit card offers 3. Failure to examine financial records

34 The Aftermath On average, victims lose between $851 and $1,378 out-ofpocket trying to resolve identity theft. (ITRC Aftermath Study, 2004) 70% of victims have difficulty removing negative information that resulted from identity theft from their credit report. (ITRC Aftermath Study, 2004) 47% of victims encounter problems qualifying for a new loan. (ITRC Aftermath Study, 2004)

35 Identifying Risks SHSU must regard any threat of identity theft as an immediate and highly important matter Steps should be taken and enforced immediately to mitigate fraud Detect Deter Defend

36 Costs to University Identity theft not only costs our students heartache, time, and money-----it impacts the university. Stolen Services Loss of Personnel Time

37 Red Flag Rules Red Flag Rule requires creditors (i.e. SHSU) to offer/maintain covered accounts to adopt a written identity theft prevention program and train its employees how to: Detect warning signs of identity theft in day to day campus operations Take Steps to Prevent identity theft on campus Mitigate any damage or liability to the students

38 Red Flag Rules SHSU campus administrators are most likely to detect Red Flags during: Admissions Process Obtaining a Bearkat OneCard Applying for Financial Aid

39 Steps to Compliance In order to comply with the Federal Red Flags Rule, SHSU had to: 1. Conduct a Risk Assessment and Potential Red Flag Areas for our campus 2. Set up procedures for detecting Red Flags 3. Respond to Red Flags instances immediately to prevent theft/mitigate damages 4. Train our employees/front line staff on the Red Flag program and how to detect

40 Prevention: Identify Red Flags Categories of Red Flags on our Campus are: 1. Presentation of suspicious documents 2. Presentation of suspicious personal identifying information 3. Suspicious account activity 4. Notice from External/Other Sources

41 How To Recognize Suspicious Documents Documents appear to have been: Altered or forged Give the appearance of having been destroyed and reassembled The person presenting the identification does not look like the photograph or match the physical description Weight Hair Color Age

42 How To Recognize Suspicious Documents & Personal Identifying Information Information on the ID differs from what the person is telling you Identifying Information on the ID is not consistent with readily accessible information in SHSU system. Address Birth date

43 Suspicious Personal Identifying Information Identifying Information means any name or number that can be used, alone or in conjunction with any other information, to identify a specific person. Includes: Name Social Security Number State or Gov. Issued ID Number Alien Registration Number Government Passport Number Employer or Taxpayer Identification Number Electronic ID Number (e.g. banking routing code)

44 Suspicious Personal Identifying Information PII provided is a type commonly associated with fraudulent activity Address is fictitious Phone number is invalid <e.g. (123) > Phone number is a pager or answering service SSN matches another student on file SSN is invalid First three digits are in the 800, 900, or 000 range In the 700 range above 772, or is 666 The fourth and fifth digits are 00 The last four digits are 0000

45 Suspicious Personal Identifying Information Student on the covered account (or student account) does not provide all the required PII during registration Student does not respond to registration being incomplete Signatures on paperwork is not consistent Student cannot provide authenticating information or answer to challenge questions beyond which is general information that could be readily accessible Wallet, Consumer report, Facebook

46 Suspicious Account Activity Mail sent to student is returned repeatedly as undeliverable Even though transactions or correspondence continues to come from that student address University is notified of unauthorized transactions in connection with a student s account The student account shows unusual activities, inconsistent with established patterns Non-payment when there is no history of this before

47 Notice from External Sources University receives notice from: Student Victims of Identity Theft Law Enforcement Authorities Other External Agency (e.g. credit bureau, etc) Student disputes a bill/student registration charge by claiming to be the victim of identity theft

48 Detection of Red Flags University administrators should exercise due diligence in the detection of Red Flags by: Asking for and verifying identification before answering questions or rendering services Being alert for Red Flags in day to day operations

49 Detection of Red Flags If students ask the reason for your identification procedures, administrators should simply explain that the procedures are for privacy reasons and to protect students security

50 Prevent & Mitigate Identity Theft Notify your Supervisor/Dept Head any time you: Encounter Suspicious documents Encounter Suspicious Personal identifying Info Suspicious Account Activity Receive notice of Red Flags or identify theft from other sources

51 Prevent & Mitigate Identity Theft If you receive a phone call from a student about a possible identity theft case or discrepancy: Request the student supply a written report to the Department Advise student to report the identity theft to local/campus police and provide University with a copy of the police report Advise student to change any and all computer passwords, security codes, and other permit access to covered accounts and/or other related financial accounts Retain copies of Documentation included with the report Note the discrepancy on student account, or in their file so that others are aware when the student is pulled up.

52 Proactive Measures-Program Oversight SHSU Red Flag Program will have ground level monitoring by Program Coordinators ANY noted potential identity theft issues should be reported IMMEDIATELY to one of the Program Coordinators The Program Coordinator will report to the Program Administrator

53 SHSU Program Oversight Team Program Administrator: Program Coordinators: VP for Finance & Operations Office of Admissions Office of Financial Aid Bursar s Office Registrar s Office Bearkat OneCard Office UPD Information Resources

54 Proactive Measures-Program Oversight Program Coordinators should: Maintain a log of incidents in their area Immediately report incidents to the Program Administrator for further investigation Show responsible for ensuring availability and compliance of departmental training Provide, on a semi-annual basis, the Program Administrator with suggested Red Flag Program updates to reflect changes in risk assessment to students

55 Proactive Measures-Program Oversight Program Administrator will: Forward any necessary case to UPD for investigation Recommend to or approve information resources to issue a new Sam ID or computer user ID for a student, when warranted Report any warranted cases to third party agencies Recommend additional training as warranted

56 Reponses to Red Flag Reports After receiving a report, possible responses include: Re-opening a covered account with a new account number/student ID Not attempting to collect on a covered account or not selling a covered account under question to Program Coordinators will report instance(s) to: Other campus administrators Law enforcement Credit Bureaus

57 Reponses to Red Flag Reports Determining no response is warranted under particular circumstances by Departmental Program Coordinator No evidence of Identity Theft is Determined Placing the covered account on hold from any further access, use, or disclosure until the Red Flag event is fully investigated by authorities Isolating and correcting inaccuracies in student records resulting from identity theft

58 Conclusion It s anticipated that most cases and subsequent investigation of detected Red Flags will be discovered and will remain at the Departmental Level Where there is a strong indication of identity theft, the Departmental Red Flag Program Coordinator will fill out a Red Flag Incident Report and send it immediately to the VPFO

59 Review Take reasonable measures to control foreseeable risks Identify Risk Factors and sources of Red Flags Detect any Red Flags through identifying information

60 Review Establish proactive measures to reduce Identity Theft Update policy as new Identity Theft risks emerge

61 References & Additional Resources Federal Register, Part IV, Federal Trade Commission 16 CFR Part 681. Federal Trade Commission. Retrieved fromhttp:// NACUBO. Retrieved from _Flags_Rule.html

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