NYU Langone Medical Center NYU Hospitals Center NYU School of Medicine
|
|
- Madlyn Bennett
- 8 years ago
- Views:
Transcription
1 Title: Identity Theft Prgram Effective Date: July 2009 NYU Langne Medical Center NYU Hspitals Center NYU Schl f Medicine POLICY It is the plicy f the NYU Langne Medical Center t educate and train staff in the early identificatin f pprtunities invlving identity theft. Staff will be trained t verify identity and t authenticate and mnitr transactins f patients, students, and staff, including validating requests fr changes f persnal infrmatin including hme addresses in cmpliance with the requirements f the FTC Red Flag Rules. Accrdingly, NYULMC has develped an Identity Theft Preventin Prgram ( Prgram ) which is designed t meet the requirements f the Rules t identify, prevent, r mitigate identity theft. This written prgram is attached t this plicy as Appendix A. PROGRAM DESIGN The Prgram is tailred t NYULMC s size, cmplexity and the nature f its peratins, and is based upn the Medical Center s previus experience with Identity Theft assciated with relevant cvered accunts. The prgram cntains mechanisms t: Identify Relevant Red Flags applicable t the type f credit extended and incrprate thse red flags int the Prgram; Detect such Red Flags; Respnd apprpriately t any Red Flags that are detected t prevent theft and mitigate damages; Ensure that the prgram is updated peridically t reflect changes in risk. The Prgrams als addresses discrepancies related t cnsumer credit reprts thrugh prcedures that: Help ensure that the persn abut whm a reprt is requested is the same as the subject f the reprt prvided by the cnsumer reprting agency; and Prvide the verified address f the subject back t the cnsumer reprting agency. PURPOSE: The U.S. Cngress has prvided prtectin fr cnsumers frm identity theft by enacting the fair and Accurate Credit Act ( FACTA ) and the Fair Credit Reprting Act ( FCRA ). FACTA directed the Federal Trade Cmmissin ( the FTC ) t issue regulatins, nw generally referred t as the Red Flag Rules ( the Rules ), which require financial institutins and creditrs t adpt plicies and prcedures that prtect cnsumers frm identity theft. Red Flags are defined by the Rules as events which shuld alert an rganizatin that there is a risk f identity theft. There are three sectins f Rules that are relevant t Hspitals: 16 C.F.R users f cnsumer reprts; (2) 16 C.F.R financial institutins and creditrs; and (3) 16 C.F.R issues f debit r credit cards. As set frth in the Definitins sectins belw, NYULMC is a user f cnsumer reprts and a creditr under the Rules, but nt an issuer f debit r credit cards. Accrdingly, NYULMC adpts this Plicy t: Identify, prevent and mitigate identity theft in cmpliance with the Rules; Apprve and establish am Identity Theft Preventin Prgram ( Prgram ) (which is attached heret as Appendix A); Appint an Identity Theft Preventin Prgram ( Prgram ) Administratr wh has primary respnsibility fr versight f the prgram. APPLICABILITY: All NYULMC persnnel invlved in the prcessing f persnally identifying infrmatin as applied t the administratin f cvered accunts. Definitins The fllwing Red Flag Rule definitins will apply t this Plicy and the Prgram: 16 C.F.R users f cnsumer reprts
2 Under the Rules, a user f cnsumer reprts is smene wh btains a cnsumer reprt frm a cnsumer reprting agency fr legally permissible purpses, such as emplyment screening r backgrund checks r credit purpses. Applicatin f Definitin: NYULMC is a user f cnsumer reprts as defined in the Rules. 16 C.F.R financial institutins and creditrs Under the Rules, a financial institutin r creditr wh ffers r maintains ne r mre cvered accunts must develp and implement a written Identity Theft Preventin Prgram that will identify, detect, prevent and mitigate damages resulting frm identity theft in cnnectin with a cvered accunt. Creditr: Fr purpses f this cmpnent f the Rules, a creditr is defined under the FCRA as...[any] persn wh regularly extends, renews, r cntinues credit; any persn wh regularly arranges fr the extensin, renewal r cntinuatin f credit, as any assignees f an riginal creditr wh participates in the decisin t extend, renew r cntinue credit. (Emphasis added). 15 U.S.C.A 1691 (a)(e). Credit: is defined as [the] right granted by a creditr t a debtr t defer payment r t incur debts and defer payment r t purchase prperty r services and defer payment therefre. 15 U.S.C.A (a)(d). Cvered accunts: are accunts [established] primarily fr persnal, family r husehld purpses that invlve r are designed t permit multiple payments f transactins, i.e. cnsumer accunts. Such accunts specifically include transactin and credit accunts, [Or] any ther accunts fr which there is a reasnably freseeable risk t custmers r the safety and sundness f the financial institutin r creditr frm identity theft. Under the Rules, Identity Theft Preventin Prgrams are nly required fr these cvered accunts. Applicatin f Definitins: NYULMC is a cvered entity under the Rules because the Medical Center acts as a creditr by ffering services fr its patients prir t receiving payment. NYULMC als regularly extends, renews, r cntinues credit and by regularly arranging fr the extensin, renewal, r cntinuatin f credit. NYULMC Cvered Accunts include all student, faculty, r staff accunts r lans fr persnal, family r husehld purpses that permit deferred r multiple payments r transactins, and are administered by the Medical Center r an authrized service prvider. These NYULMC cvered accunts include lans t students, Deferred Tuitin Payments Plans, and funds due based n patient care services. 16 C.F.R issuers f debit r credit cards Under the Rules, issuers f debit and credit cards must develp plicies and prcedures t asses the validity f a request fr a change f address that is fllwed clsely by a request fr an additinal r replacement card. Debit Card: means any card issued by a financial institutin t a cnsumer fr use in initiating an electrnic fund transfer frm the accunt f the cnsumer at such financial institutin, fr the purpse f transferring mney between accunts r btaining mney, prperty, labr, r services. 15 U.S.C. 1681a (3) Applicatin f Definitins: NYULMC des nt issue debit r credit cards. The prvisin f the Rules des nt apply t meal cards issues thrugh the CBORD system fr use in the hspital cafeterials and fd carts While these cards have sme debit card functinality, they are stred value cards under the Rules rather than debit cards. Other Relevant Definitins Identifying Infrmatin: is any name r number that may be used alne r in cnjunctin with any ther infrmatin t identify a specific persn, including: name, address, telephne number, scial security number, date f birth, driver s license r identificatin number, alien registratin number, passprt number, emplyer r taxpayer identificatin number.
3 Identity Theft: is a fraud cmmitted r attempted using the identifying infrmatin f anther persn withut authrity. Red Flag: is a pattern, practice r specific activity that indicates the ptential fr Identity theft. Prgram Administratr: is the individual designated by the Senir Vice President fr Finance and Budget t have primary respnsibility fr versight f the Prgram. Apprved by: PCQAOC, September 16, 2009
4 APPENDIX A The Identity Theft Prevent Prgram I Identificatin f Red Flags T identify relevant Red Flags, the NYULMC cnsiders the types f Cvered Accunts that it ffers and maintains; the methds it prvides t pen and access the Cvered Accunts, including in-persn, mailed r nline methds, and the NYULMC s previus experience with Identity Theft. NYULMC ffers lans t students, and deferred payment plans. NYULMC als has patient billing and infrmatin accunts. These prgrams may invlve accunts that qualify as cvered accunts. The MC has cnsequently identified the fllwing Red Flags: Ntificatins r Warnings frm Cnsumer/credit Reprting Agencies: Alerts, ntificatins, r ther warnings received frm cnsumer reprting agencies r service prviders indicating: A credit freeze; Active duty alert; Address discrepancy in respnse t a credit reprt request, and Activity that is incnsistent with the usual pattern r activity f the accunt hlder. Suspicius Dcuments: Presentatin f suspicius dcuments which appear t be alerted, frged r inauthentic, including incnsistent appearance f phtgraphs r physical descriptin n a dcument with the persn presenting it. Suspicius Persnal Identifying Infrmatin: Presentatin f incnsistent persnal indentifying infrmatin such as: An incnsistent birth date; An address that des nt match a prir address submitted n an applicatin; A scial security number, telephne number r address that is the same as that given by anther accunt hlder; r Repeated failure t prvide identifying infrmatin n an applicatin. Suspicius Use r Activity in Cvered Accunt: Unusual use f r ther suspicius activity related t a cvered accunt including, but nt limited t: Requests made frm nn-issued accunt; Unfficial frms which are presented with requests fr infrmatin; Mail returned as undeliverable; r Ntice f change in payments fr an therwise cnsistent backgrund infrmatin prvided; The same identificatin used by multiple family members fr patient services; Used an identificatin that des nt match the presenting individual; Cmplaint frm a recipient f healthcare services based n receipt f: A bill fr anther individual A bill fr a prduct r service the patient denies receiving A bill frm a healthcare prvider that the patient never patrnized; A ntice frm insurance benefits (r Explanatin f Benefits) fr healthcare services never received. Alerts frm Others: Ntice frm an accunt hlder, victim f identity theft r law enfrcement authrities that the Medical Center has pened r is maintaining fraudulent accunt fr a persn engaged Identity Theft. II Detectin f Red Flags The Prgram is required t establish prcedures fr the detectin f Red Flags in the designated areas f activity. These prcedures are set frth belw: Opening f Cvered Accunts: Identity verificatin f first-time accunt hlders will be required, including presentatin f identifying infrmatin such as name, date f birth, academic recrds r insurance card, and hme address, which will be subsequently verified by review f driver s license, passprt, r ther gvernment-issued pht identificatin ad insurance cmpany infrmatin.
5 Risk Assessment: A minimal number f instances f Identity Theft have been identified and reprted as required by NYS regulatin. Existing Cvered Accunts: Authenticatin f accunt hlders and mnitring f transactins n the cvered accunt will be required, including: Verificatin f the identity f accunt hlders if they request infrmatin (in persn, via telephne, via facsimile, via ); Verificatin f changes in banking infrmatin given fr billing r payment purpses: Requests fr billing address changes fr Cvered Accunts must be verified and means prvided t accunt hlders fr ntificatin f changed r incrrect billing addresses; Requests fr medical recrds (identity shuld match pht) n file/identificatin card) must include all apprpriate release frms; Patients arriving fr treatment need t prvide prf f identity by gvernment issued identificatin r insurance card cpied and checked against data in existing recrds; Name, gender, and DOB matched against the patient presenting insurance card; Risk Assessment: N Identity Theft has been experienced by NYULMC while maintaining the identified NYULMC cvered accunts. Cnsumer / Credit Reprt Requests: When a cnsumer/credit reprt request results in ntice f address discrepancy frm the reprting agency, Medical Center persnnel will request written verificatin frm the subject f the reprt that the address he/she prvided is accurate, and nce and address is verified, Medical Center persnnel will reprt such address t the reprting agency. III IV V Respnses t Red Flags In respnse t the detectin f Red Flags, Medical Center persnnel will take the apprpriate actin t prevent and mitigate Identity Theft depending upn degree f risk psed by the Red Flags, including: Mnitring a Cvered fr suspicius activity; Denying access t the Cvered Accunt until infrmatin is verified t eliminate Red Flags; Cntacting the accunt hlder t verify activity in the Cvered Accunt: Changing passwrds, security cdes r ther security devices; Clsing and repening the Cvered Accunt; Refuse t pen a new Cvered Accunt; Ntifying law enfrcement; Determining that n respnse is warranted upn reasnable investigatin f the particular circumstances. Updating The Prgram NYULMC shall update this Prgram (including the Red Flags determined t be relevant) peridically, t reflect changes in risks t students, faculty members, r thers r t the safety and sundness f NYULMC frm identity based n such factrs as: The experiences f NYULMC with identity theft; Changes in methds f identity theft; Changes in methds t detect, prevent, and mitigate identity theft; Changes in the types f accunts that NYULMC, including mergers, acquisitins, alliances, jint ventures, and service prvider arrangements. Methds Fr Administering The Prgram Oversight f Prgram: This prgram shall be verseen by the Audit and Cmpliance Cmmittee f the Bard f Trustees. This versight shall include: Implementatin f the prgram by the Senir Vice President fr Finance r designee; Reprts prepared by staff regarding cmpliance by NYULMC with the Identity Theft Preventin Plicy and Prgram shall be reviewed by the Senir Vice President fr Finance r designee and the Vice President f Audit and Cmpliance with findings presented t the Audit and Cmpliance Cmmittee; and Material changes t the Prgram as necessary t address changing Identity Theft risks shall be apprved by the Audit and Cmpliance Cmmittee.
6 Staff Training and Reprting: NYULMC persnnel will be trained by r under the directin f the Prgram Administratr t effectively implement the Prgram and detect and respnd t Red Flags. NYULMC will ntify the Prgram Administratr f any incident f Identity Theft r the Medical Center s failure t cmply with the Prgram. Medical Center persnnel designated by the Prgram Administratr will reprt t the Prgram Administratr at least annually, r as requested. Such reprts will include, amng ther relevant issues: The effectiveness f the specific plicies and prcedures fr addressing the current risks f Identity Theft in cnnectin with the Cvered Accunts; Any significant incidents invlving Identity Theft and the respnse taken; and Recmmendatins fr material changes t the Prgram. Oversight f Service Prviders: In the event that the Medical Center cntracts with an utside service prvider t perfrm any activity in cnnectin with Cvered Accunts, the Medical Center will ensure that: The service prvider s activities are cnducted in accrdance with reasnable plicies and prcedures designed t detect, prevent and mitigate risk f Identity Theft and; The service prvider reviews the Prgram and reprts and Red Flags t the Prgram Administratr r the designated Medical Center persnnel with primary versight f the service relatinship. Apprved by: PCQAOC, September 16, 2009
THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM
THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM 1. Prgram Adptin The City University f New Yrk (the "University") develped this Identity Theft Preventin Prgram (the "Prgram") pursuant
More informationFAYETTEVILLE STATE UNIVERSITY
FAYETTEVILLE STATE UNIVERSITY IDENTITY THEFT PREVENTION (RED FLAGS RULE) Authrity: Categry: Issued by the Fayetteville State University Bard f Trustees. University-Wide Applies t: Administratrs Faculty
More informationInformation Security Policy
Purpse The risk t Charlestn Suthern University, its emplyees and students frm data lss and identity theft is f significant cncern t the University and can be reduced nly thrugh the cmbined effrts f every
More informationFighting Identity Theft with the Red Flags Rule: A How-To Guide for Business
This infrmatin prvided by the Federal Trade Cmmissin. (http://business.ftc.gv/dcuments/bus23-fighting-identity-theft-red-flags-rule-hw-guide-business) Fighting Identity Theft with the Red Flags Rule: A
More informationFAFSA / DREAM ACT COMPLETION PROGRAM AGREEMENT
FAFSA / DREAM ACT COMPLETION PROGRAM AGREEMENT If using US Pstal Service, please return t: Califrnia Student Aid Cmmissin Prgram Administratin & Services Divisin ATTN: Institutinal Supprt P.O. Bx 419028
More informationTexas Woman's University University Policy Manual
Texas Wman's University University Plicy Manual Plicy Name: Plicy Number: 6.06 Date Passed: July 2004 Health Insurance Prtability& Accuntability Act (HIPAA) Date Reviewed: September 2008 Next Review: September
More informationKey Steps for Organizations in Responding to Privacy Breaches
Key Steps fr Organizatins in Respnding t Privacy Breaches Purpse The purpse f this dcument is t prvide guidance t private sectr rganizatins, bth small and large, when a privacy breach ccurs. Organizatins
More informationPlus500CY Ltd. Statement on Privacy and Cookie Policy
Plus500CY Ltd. Statement n Privacy and Ckie Plicy Statement n Privacy and Ckie Plicy This website is perated by Plus500CY Ltd. ("we, us r ur"). It is ur plicy t respect the cnfidentiality f infrmatin and
More informationNAIC Replacement Requirements For Certain Life Insurance Policies And Annuity Contracts
NAIC Replacement Requirements Fr Certain Life Insurance Plicies And Annuity Cntracts Duties f Prducers If a transactin invlves a replacement, the prducer must leave with the applicant, at the time an applicatin
More informationAudit Committee Charter
Audit Cmmittee Charter Membership The Audit Cmmittee (the "Cmmittee") f the Bard f Directrs (the "Bard") f Philip Mrris Internatinal Inc. (the "Cmpany") shall cnsist f at least three directrs all f whm
More informationHampton Roads Orthopaedics & Sports Medicine. Notice of Privacy Practices
This is being prvided t yu as a requirement f the privacy regulatins issued under the Health Insurance Prtability and Accuntability Act f 1996 (HIPAA). This ntice describes hw HROSM may use and disclse
More informationMunicipal Advisor Registration
FACT SHEET Municipal Advisr Registratin SEC Open Meeting Sept. 18, 2013 The Securities and Exchange Cmmissin tday will cnsider whether t adpt a rule that wuld establish a permanent registratin regime fr
More informationGUIDANCE FOR BUSINESS ASSOCIATES
GUIDANCE FOR BUSINESS ASSOCIATES This Guidance fr Business Assciates dcument is intended t verview UPMCs expectatins, as well as t prvide additinal resurces and infrmatin, t UPMC s HIPAA business assciates.
More informationIdentity Theft Prevention Program (ITPP) under the FTC FACTA Red Flags Rule PROCEDURES DOCUMENT. I. Purpose/Scope... 1
Identity Theft Preventin Prgram (ITPP) under the FTC FACTA Red Flags Rule PROCEDURES DOCUMENT Table f Cntents I. Purpse/Scpe... 1 II. ITPP Apprval and Administratin... 2 III. Relatinship t Other University
More informationTHIRD PARTY PROCUREMENT PROCEDURES
ADDENDUM #1 THIRD PARTY PROCUREMENT PROCEDURES NORTH CENTRAL TEXAS COUNCIL OF GOVERNMENTS TRANSPORTATION DEPARTMENT JUNE 2011 OVERVIEW These prcedures establish standards and guidelines fr the Nrth Central
More informationDisplayNote Technologies Limited Data Protection Policy July 2014
DisplayNte Technlgies Limited Data Prtectin Plicy July 2014 1. Intrductin This dcument sets ut the bligatins f DisplayNte Technlgies Limited ( the Cmpany ) with regard t data prtectin and the rights f
More informationMSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER
MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER This Audit Cmmittee Charter has been amended as f July 17, 2015. The Audit Cmmittee shall review and reassess this Charter annually and recmmend
More informationVCU Payment Card Policy
VCU Payment Card Plicy Plicy Type: Administrative Respnsible Office: Treasury Services Initial Plicy Apprved: 12/05/2013 Current Revisin Apprved: 12/05/2013 Plicy Statement and Purpse The purpse f this
More informationSources of Federal Government and Employee Information
Inf Surce Surces f Federal Gvernment and Emplyee Infrmatin Ridley Terminals Inc. TABLE OF CONTENTS General Infrmatin Intrductin t Inf Surce Backgrund Respnsibilities Institutinal Functins, Prgram and Activities
More informationWHAT YOU NEED TO KNOW ABOUT. Protecting your Privacy
WHAT YOU NEED TO KNOW ABOUT Prtecting yur Privacy YOUR PRIVACY IS OUR PRIORITY Credit unins have a histry f respecting the privacy f ur members and custmers. Yur Bard f Directrs has adpted the Credit Unin
More informationUniversity of Texas at Dallas Policy for Accepting Credit Card and Electronic Payments
University f Texas at Dallas Plicy fr Accepting Credit Card and Electrnic Payments Cntents: Purpse Applicability Plicy Statement Respnsibilities f a Merchant Department Prcess t Becme a Merchant Department
More informationUNIVERSITY OF WINCHESTER
UNIVERSITY OF WINCHESTER INTRODUCTION DEBT MANAGEMENT POLICY: STUDENTS ACADEMIC YEAR 15/16 This dcument sets ut the plicy f the University in relatin t student debt, alng with the debt management prcedures
More informationKentwood Police Department 4742 Walma Ave SE Kentwood, Michigan 49512 (616) 698-6580 http://www.ci.kentwood.mi.us REPORTING IDENTITY THEFT
Kentwd Plice Department 4742 Walma Ave SE Kentwd, Michigan 49512 (616) 698-6580 http://www.ci.kentwd.mi.us REPORTING IDENTITY THEFT If yu are the victim f identity theft and ne f the fllwing cnditins are
More informationCredit Work Group Recommendation
Credit Wrk Grup Recmmendatin T: Credit Wrk Grup Frm: Mike Bixby (305) 829-5549 mbixby@inf1team.cm Paul Wills (770) 740-7353 Paul.Wills@equifax.cm Date: Octber 7, 2004 Re: FACT Act Implicatins and Recmmendatins
More informationMulti-Year Accessibility Policy and Plan for NSF Canada and NSF International Strategic Registrations Canada Company, 2014-2021
Multi-Year Accessibility Plicy and Plan fr NSF Canada and NSF Internatinal Strategic Registratins Canada Cmpany, 2014-2021 This 2014-21 accessibility plan utlines the plicies and actins that NSF Canada
More informationPeratr Accreditatin and Services in Queensland
Infrmatin Bulletin PT 204/09.15 Operatr Accreditatin fr Limusine Services What is peratr accreditatin? The Transprt Operatins (Passenger Transprt) Act 1994 requires peratrs f public passenger services
More informationFINANCIAL OPTIONS. 2. For non-insured patients, payment is due on the day of service.
FINANCIAL OPTIONS 1. Fr thse patients wh carry dental insurance, all c-payments are due n date f service. We will file yur claim as a service t yu, and will d ur very best t maximize yur benefits. We accept
More informationProject Open Hand Atlanta. Health Insurance Portability and Accountability Act (HIPAA) NOTICE OF PRIVACY PRACTICES
Prject Open Hand Atlanta Effective Date: April 14, 2003 Health Insurance Prtability and Accuntability Act (HIPAA) The Health Insurance Prtability and Accuntability Act f 1996 (HIPAA) directs health care
More informationGeneral Records Authority 33. Accredited Training
General Recrds Authrity 33 2012/00579704 Accredited Training February 2013 This is an accurate reprductin f the authrised recrds authrity cntent, created fr accessibility purpses CONTENTS INTRODUCTION
More informationCHARTER OF THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS OF UPLAND SOFTWARE, INC.
CHARTER OF THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS OF UPLAND SOFTWARE, INC. PURPOSE The purpse f the Cmpensatin Cmmittee f the Bard f Directrs (the Bard ) f Upland Sftware, Inc. (the Cmpany
More informationHIPAA Notice of Privacy Practices. Central Ohio Surgical Associates, Inc.
HIPAA Ntice f Privacy Practices Central Ohi Surgical Assciates, Inc. THIS NOTICE OF PRIVACY PRACTICES (THE NOTICE ) DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN
More informationInteragency Guidance on Privacy Laws and Reporting Financial Abuse of Older Adults
Bard f Gvernrs f the Federal Reserve System Cmmdity Futures Trading Cmmissin Cnsumer Financial Prtectin Bureau Federal Depsit Insurance Crpratin Federal Trade Cmmissin Natinal Credit Unin Administratin
More informationGOVERNORS PHARMACY HIPAA NOTICE OF PRIVACY PRACTICES For Your Protected Health Information
GOVERNORS PHARMACY HIPAA NOTICE OF PRIVACY PRACTICES Fr Yur Prtected Health Infrmatin THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS
More informationProcess for Responding to Privacy Breaches
Prcess fr Respnding t Privacy Breaches 1. Purpse 1.1 This dcument sets ut the steps that ministries must fllw when respnding t a privacy breach. It must be read in cnjunctin with the Infrmatin Incident
More informationCOMPLIANCE WITH THE FEDERAL TRADE COMMISSION S SAFEGUARDS RULE
COMPLIANCE WITH THE FEDERAL TRADE COMMISSION S SAFEGUARDS RULE COMPLIANCE WITH THE FEDERAL TRADE COMMISSION S SAFEGUARDS RULE Mst dealers are familiar with the requirements f the Gramm-Leach-Bliley Act
More informationo o 2) Program Rewards
1) T qualify fr the American Red Crss High Schl Leadership Prgram (referred t as Prgram), each student (referred t as Member) is asked t cmplete the fllwing requirements: a. Cmplete an nline prfile at
More informationERISA Compliance FAQs: Fiduciary Responsibilities
Brught t yu by Mrris & Reynlds Insurance ERISA Cmpliance FAQs: Fiduciary Respnsibilities The Emplyee Retirement Incme Security Act f 1974 (ERISA) is a federal law that sets minimum standards fr emplyee
More informationTrustED Briefing Series:
TrustED Briefing Series: Since 2001, TrustCC has prvided IT audits and security assessments t hundreds f financial institutins thrugh ut the United States. Our TrustED Briefing Series are white papers
More informationRQ10.06 AACo Share Trading Policy
Australian Agricultural Cmpany Limited ACN 010 892 270 RQ10.06 AAC Share Trading Plicy Versin 5 This plicy was apprved by the Bard f Australian Agricultural Cmpany Limited n 15 December 2010. This plicy
More informationFIREFIGHTER HEART AND CIRCULATORY MALFUNCTION BENEFITS PROGRAM STANDARD OPERATING GUIDELINES Approved by the DOLA Executive Director July 1, 2014
FIREFIGHTER HEART AND CIRCULATORY MALFUNCTION BENEFITS PROGRAM STANDARD OPERATING GUIDELINES Apprved by the DOLA Executive Directr July 1, 2014 Prgram Overview: As f July 1, 2014, the Department f Lcal
More informationThis regulation is adopted by the director pursuant to the authority in Neb. Rev. Stat. 44-1114.
Title 210 NEBRASKA DEPARTMENT OF INSURANCE Chapter 76 VIATICAL SETTLEMENTS 001. Authrity This regulatin is adpted by the directr pursuant t the authrity in Neb. Rev. Stat. 44-1114. 002. Definitins In additin
More informationOnline Banking Agreement
Online Banking Agreement 1. General This Online Banking Agreement, which may be amended frm time t time by us (this "Agreement"), fr accessing yur Clrad Federal Savings Bank accunt(s) via the Internet
More informationIMT Standards. Standard number A000014. GoA IMT Standards. Effective Date: 2010-09-30 Scheduled Review: 2011-03-30 Last Reviewed: Type: Technical
IMT Standards IMT Standards Oversight Cmmittee Gvernment f Alberta Effective Date: 2010-09-30 Scheduled Review: 2011-03-30 Last Reviewed: Type: Technical Standard number A000014 Electrnic Signature Metadata
More informationDear Flexible Spending Account (FSA) Enrollee:
Dear Flexible Spending Accunt (FSA) Enrllee: Welcme t yur FSA Plan! Yu nw have 24x7 access t all yur FSA needs n the web. T access yur accunt simply lgn t www.fsa4me.cm. Yur user name is yur first initial,
More informationJohnston Public Schools Special Education Procedural Manual. IEP Overview
Jhnstn Public Schls Special Educatin Prcedural Manual IEP Overview Definitin The Individualized Educatin Prgram (IEP) is a written plan fr the apprpriate educatin f students with disabilities. It is a
More informationNSW FAIR TRADING. Real Estate Fraud Prevention Guidelines
NSW FAIR TRADING Real Estate Fraud Preventin Guidelines Real Estate Fraud Preventin Guidelines Cntents 1. Intrductin..... 2 2. Backgrund.. 2 3. The Law.. 2 4. Cmmissiner s Guidance.... 3 5. Prescribed
More informationMunising Memorial Hospital. Administrative/Financial Policy
Munising Memrial Hspital Administrative/Financial Plicy SUBJECT: Credit and Cllectins & Financial Assistance POLICY NO. 100-072 REVISED: March 26, 2014 Authrized By: The credit and cllectin plicy f Munising
More informationFirst Global Data Corp.
First Glbal Data Crp. Privacy Plicy As f February 23, 2015 Ding business with First Glbal Data Crp. ("First Glbal", First Glbal Mney, "we" r "us", which includes First Glbal Data Crp. s subsidiary, First
More informationBLUE RIDGE COMMUNITY AND TECHNICAL COLLEGE BOARD OF GOVERNORS
BLUE RIDGE COMMUNITY AND TECHNICAL COLLEGE BOARD OF GOVERNORS SERIES: 1 General Rules RULE: 17.1 Recrd Retentin Scpe: The purpse f this rule is t establish the systematic review, retentin and destructin
More informationHow To Ensure Your Health Care Is Safe
Guidelines fr Custdians t assess cmpliance with the Persnal Health Infrmatin Privacy and Access Act (PHIPAA) This dcument is designed t help custdians evaluate readiness fr cmpliance with PHIPAA and t
More informationPrivacy and Security Training Policy (PS.Pol.051)
Privacy and Security Training Plicy (PS.Pl.051) Purpse T define the plicies and prcedures fr prviding privacy and security training in respect f the CnnectingGTA Slutin. Definitins Electrnic Service Prvider
More informationTexas Department of Insurance Division of Workers Compensation. Insurance Carrier/Utilization Review Agent Plan-Based Audit
Texas Department f Insurance Divisin f Wrkers Cmpensatin Insurance Carrier/Utilizatin Review Agent Plan-Based Audit Octber 22, 2012 1 P age Sectin I: General Statement and Overview The Texas Department
More informationNursing Pragdocs and Freign Instituteutins - A Review
Statutry Authrity As prvided under sectin 498 f the Higher Educatin Act f 1965, as amended (Title IV, HEA prgrams), the Secretary determines whether freign institutins chsing t participate r participating
More informationOur Privacy Policy and Credit Reporting Privacy Policy. 1. Privacy at FlexiGroup Our Privacy Policy and Credit Reporting Privacy Policy
Our Privacy Plicy and Credit Reprting Privacy Plicy 1. Privacy at FlexiGrup Our Privacy Plicy and Credit Reprting Privacy Plicy Backgrund At Flexigrup it is imprtant t us that we manage yur persnal infrmatin
More informationES PROCEDURES FOR OVERPAYMENT RECOVERY
ES PROCEDURES FOR OVERPAYMENT RECOVERY Effective: 7/1/2012 Respnsible Office: Emplyee Services (ES) Apprved: ES Directr Applicatin: All Emplyees f the University f Clrad Plicy The University f Clrad will
More informationMerchant Processes and Procedures
Merchant Prcesses and Prcedures Table f Cntents EXHIBIT C 1. MERCHANT INTRODUCTION TO T-CHEK 3 1.1 Wh is T-Chek Systems? 3 1.2 Hw t Cntact T-Chek Systems 3 1.3 Hw t Recgnize T-Chek Frms f Payment 3 1.3.1
More informationScotiabank Group Privacy Agreement
Sctiabank Grup Privacy Agreement Last revised Octber 2010 Yur privacy is imprtant t Sctiabank. This Agreement sets ut the infrmatin practices fr Sctiabank Grup Members in Canada, including what type f
More informationRUTGERS POLICY. Responsible Executive: Vice President for Information Technology and Chief Information Officer
RUTGERS POLICY Sectin: 70.1.1 Sectin Title: Infrmatin Technlgy Plicy Name: Acceptable Use Plicy fr Infrmatin Technlgy Resurces Frmerly Bk: N/A Apprval Authrity: Senir Vice President fr Administratin Respnsible
More informationHIPAA Compliance 101. Important Terms. Pittsburgh Computer Solutions 724-942-1337
HIPAA Cmpliance 101 Imprtant Terms Cvered Entities (CAs) The HIPAA Privacy Rule refers t three specific grups as cvered entities, including health plans, healthcare clearinghuses, and health care prviders
More informationAudit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd
Audit Cmmittee Charter St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd Versin 2.0, 22 February 2016 Apprver Bard f Directrs St Andrew
More informationColumbine Federal Credit Union ONLINE BANKING/ BILL PAYMENT AGREEMENT & DISCLOSURES AND PRIV ACY DISCLOSURE
Clumbine Federal Credit Unin ONLINE BANKING/ BILL PAYMENT AGREEMENT & DISCLOSURES AND PRIV ACY DISCLOSURE 1. Online Banking/Bill Payment 2. Online Banking/ Bill Payment Limitatins 3. Online Bill Payment
More informationSymantec User Authentication Service Level Agreement
Symantec User Authenticatin Service Level Agreement Overview and Scpe This Symantec User Authenticatin service level agreement ( SLA ) applies t Symantec User Authenticatin prducts/services, such as Managed
More informationMontana Acquisition & Contracting System (emacs) emacs Handbook. Vendor Registration and Data Management
Mntana Acquisitin & Cntracting System (emacs) emacs Handbk Vendr Registratin and Data Management Welcme The purpse f this emacs Handbk fr Vendr Registratin and Data Management is t prvide vendrs with the
More informationSystems Support - Extended
1 General Overview This is a Service Level Agreement ( SLA ) between and the Enterprise Windws Services t dcument: The technlgy services the Enterprise Windws Services prvides t the custmer. The targets
More informationPOLICY 1390 Information Technology Continuity of Business Planning Issued: June 4, 2009 Revised: June 12, 2014
State f Michigan POLICY 1390 Infrmatin Technlgy Cntinuity f Business Planning Issued: June 4, 2009 Revised: June 12, 2014 SUBJECT: APPLICATION: PURPOSE: CONTACT AGENCY: Plicy fr Infrmatin Technlgy (IT)
More informationAppendix 5. Arkansas Insurance Department Network Adequacy Guidelines and Targets
Appendix 5 Arkansas Insurance Department Netwrk Adequacy Guidelines and Targets ACHI is a nnpartisan, independent, health plicy center that serves as a catalyst t imprve the health f Arkansans. 1401 West
More informationFORM ADV (Paper Version) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS
APPENDIX A FORM ADV (Paper Versin) UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT FORM BY EXEMPT REPORTING ADVISERS Frm ADV: General Instructins Read these instructins carefully befre
More informationGENERAL MOTORS COMPANY AUDIT COMMITTEE CHARTER. Most Recently Amended: December 8, 2015
GENERAL MOTORS COMPANY AUDIT COMMITTEE CHARTER Mst Recently Amended: December 8, 2015 Purpse The purpse f the Audit Cmmittee is t assist the Bard f Directrs f General Mtrs Cmpany in its versight f the
More informationLOUISIANA TECH UNIVERSITY Division of Student Financial Aid Post Office Box 7925 Ruston, LA 71272
LOUISIANA TECH UNIVERSITY Divisin f Student Financial Aid Pst Office Bx 7925 Rustn, LA 71272 Dear Financial Aid Applicant, Accrding t yur 2011-2012 Student Aid Reprt (SAR), yu did nt include any parental
More informationWhat Information Is Collected and How Is It Collected?
RCI PRIVACY NOTICE RCI Pacific Pty Ltd is cncerned abut privacy issues and wants yu t be familiar with hw we cllect, use and disclse infrmatin. This Privacy Ntice describes ur practices in cnnectin with
More informationInvestment Adviser Switch Workshop
Investment Adviser Switch Wrkshp Investment Adviser Registratin, Renewal, Amendment And Pst-Registratin Requirements Presented by Office f the Attrney General Maryland Divisin f Securities 1 Registratin
More informationIf the CAP is acceptable, the serious deficiency determination for the provider is temporarily deferred.
Pat McCrry Gvernr Sent Via Email TO: FROM: Nrth Carlina Department f Health and Human Services Divisin f Public Health May 12.2014 Spnsring Organizatins f Day Care Hmes Arnette Cwan, MS, RD, LDN Supervisr,
More informationMAYFAIR INSURANCE & MORTGAGE CONSULTANTS LTD 11 Lurke Street, Bedford MK40 3HZ Telephone: 01234 242900
MAYFAIR INSURANCE & MORTGAGE CONSULTANTS LTD 11 Lurke Street, Bedfrd MK40 3HZ Telephne: 01234 242900 Please read this dcument carefully as it sets ut the terms n which we agree t act fr ur clients and
More informationPENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK
Department f Health and Human Services OFFICE OF INSPECTOR GENERAL PENETRATION TEST OF THE INDIAN HEALTH SERVICE S COMPUTER NETWORK Inquiries abut this reprt may be addressed t the Office f Public Affairs
More informationTITLE: RECORDS AND INFORMATION MANAGEMENT POLICY
TITLE: RECORDS AND INFORMATION MANAGEMENT POLICY REFERENCE NUMBER: 14/103368 RESPONSIBLE DEPARTMENT: Crprate Services APPLICABLE LEGISLATION: State Recrds Act 1997 Lcal Gvernment Act 1999 Crpratins Act
More informationCLEARANCE REVIEWS FOR STUDENT RESTRICTION ISSUES OTHER THAN ACADEMIC PROGRESS
CLEARANCE REVIEWS FOR STUDENT RESTRICTION ISSUES OTHER THAN ACADEMIC PROGRESS Only the Ministry f Training, Clleges & Universities can cnsider clearance reviews fr mst ther student restrictin issues. These
More informationHeythrop College Disciplinary Procedure for Support Staff
Heythrp Cllege Disciplinary Prcedure fr Supprt Staff Intrductin 1. This prcedural dcument des nt apply t thse academic-related staff wh are mentined in the Cllege s Ordinance, namely the Librarian and
More informationHillsborough Board of Education Acceptable Use Policy for Using the Hillsborough Township Public Schools Network
2361/Page 1 f 8 Hillsbrugh Bard f Educatin Acceptable Use Plicy fr Using the Hillsbrugh Twnship Public Schls Netwrk The Bard f Educatin recgnizes as new technlgies shift the manner in which infrmatin is
More informationRequest for Resume (RFR) CATS II Master Contract. All Master Contract Provisions Apply
Sectin 1 General Infrmatin RFR Number: (Reference BPO Number) Functinal Area (Enter One Only) F50B3400026 7 Infrmatin System Security Labr Categry A single supprt resurce may be engaged fr a perid nt t
More informationCMS Eligibility Requirements Checklist for MSSP ACO Participation
ATTACHMENT 1 CMS Eligibility Requirements Checklist fr MSSP ACO Participatin 1. General Eligibility Requirements ACO participants wrk tgether t manage and crdinate care fr Medicare fee-fr-service beneficiaries.
More informationPersonal Data Security Breach Management Policy
Persnal Data Security Breach Management Plicy 1.0 Purpse The Data Prtectin Acts 1988 and 2003 impse bligatins n data cntrllers in Western Care Assciatin t prcess persnal data entrusted t them in a manner
More informationITRC Fact Sheet 117 Identity Theft and the Deceased: Prevention and Victim Tips
ITRC Fact Sheet 117 Identity Theft and the Deceased: Preventin and Victim Tips This guide will address several areas: Steps t take t decrease identity theft risk when a lved ne passes away Specific instructins
More informationHillsborough Board of Education Acceptable Use Policy for Using the Hillsborough Township Public Schools Network
2361/Page 1 f 6 Hillsbrugh Bard f Educatin Acceptable Use Plicy fr Using the Hillsbrugh Twnship Public Schls Netwrk It is the gal f the HTPS (Hillsbrugh Twnship Public Schls) Netwrk t prmte educatinal
More informationE-Business Strategies For a Cmpany s Bard
DATATEC LIMITED BOARD CHARTER / TERMS OF REFERENCE 1. CONSTITUTION The primary bjective f the Cmpany s Bard Charter is t set ut the rle and respnsibilities f the Bard f Directrs ( the Bard ) as well as
More informationCOPIES-F.Y.I., INC. Policies and Procedures Data Security Policy
COPIES-F.Y.I., INC. Plicies and Prcedures Data Security Plicy Page 2 f 7 Preamble Mst f Cpies FYI, Incrprated financial, administrative, research, and clinical systems are accessible thrugh the campus
More informationApplication for 477 Services
An Indian Rerganizatin Act Village Under Act f Cngress June 15 th, 1935 32 Chilkat Ave. Klukwan, Alaska 99827 HC60 Bx 2207 Haines, Alaska 99827 Phne: 907-767-5505 Fax: 907-767-5408 klukwan@chilkat-nsn.gv
More informationAIG Annuities Fixed and Income
AIG Annuities Fixed and Incme We wuld like t make yur experience f becming an AIG Annuities Fixed and Incme partner an easy ne. Please find enclsed r attached (if received via email) the fllwing dcuments
More information0820.02 Workers Disability Compensation Claims Procedures Issued: January 1, 1994 Revised: March 29, 2012
State f Michigan Administrative Guide t State Gvernment 0820.02 Wrkers Disability Cmpensatin Claims Prcedures Issued: January 1, 1994 Revised: March 29, 2012 SUBJECT: APPLICATION: PURPOSE: CONTACT AGENCY:
More informationState Fleet Card Oversight Usage and Responsibilities
State Fleet Card Oversight Usage and Respnsibilities Intrductin The Department f General Services (DGS), Office f Fleet and Asset Management (OFAM) administers a statewide ne-prvider payment system cntract
More informationCreating an Ethical Culture and Protecting Your Bottom Line:
Creating an Ethical Culture and Prtecting Yur Bttm Line: Best Practices fr Crprate Cdes f Cnduct Nte: The infrmatin belw and all infrmatin n this website is nt meant t be taken as legal advice. Please
More informationCORPORATE CREDIT CARD POLICY
TITLE: POLICY OWNERS: DATE INSTITUTED: May 1, 2008 CURRENT VERSION: Ver. 1.6 REVISION DATE: July 1, 2015 Crprate Credit Card Plicy Melissa Cluse, Vice President & Cntrller Cindy Klein, Accunts Payable
More informationFINANCIAL SERVICES FLASH REPORT
FINANCIAL SERVICES FLASH REPORT Draft Regulatry Cmpliance Management Guideline Released by the Office f the Superintendent f Financial Institutins May 5, 2014 On April 30, 2014, the Office f the Superintendent
More informationMANUAL OF UNIVERSITY POLICIES PROCEDURES AND GUIDELINES. HIPAA: Use and Disclosure of Protected Health Information
Page 1 f 23 HIPAA: Use and Disclsure f Prtected Health Infrmatin Applies t: faculty staff students student emplyees visitrs cntractrs clinicians Effective Date f This Revisin: Nvember 27, 2012 Cntact fr
More informationPrivacy Policy. The Central Equity Group understands how highly people value the protection of their privacy.
Privacy Plicy The Central Equity Grup understands hw highly peple value the prtectin f their privacy. Fr that reasn, the Central Equity Grup takes particular care in dealing with any persnal and sensitive
More informationDATE APPROVED March 2011. Version Date Comments / Changes 1.0 March 2011 Initial policy released
Page 1 f 11 APPROVED (S) REVISED / REVIEWED SUMMARY Versin Date Cmments / Changes 1.0 Initial plicy released 1. PURPOSE OF THIS POLICY T define the purpses fr which Crprate Purchase Cards are t be used
More informationFrequently Asked Questions about the Faith A. Fields Nursing Scholarship Loan
ARKANSAS STATE BOARD OF NURSING 1123 S. University Avenue, Suite 800, University Twer Building, Little Rck, AR 72204 Phne: (501) 686-2700 Fax: (501) 686-2714 www.arsbn.rg Frequently Asked Questins abut
More informationTO: Chief Executive Officers of all National Banks, Department and Division Heads, and all Examining Personnel
AL 96-7 Subject: Credit Card Preapprved Slicitatins TO: Chief Executive Officers f all Natinal Banks, Department and Divisin Heads, and all Examining Persnnel PURPOSE The purpse f this advisry letter is
More informationAccessible Service Policy
Accessible Service Plicy Date Created Revisin Oct. 16, 2012 1 Gal This plicy is intended t meet the requirements f the Accessibility Standards fr Custmer Service, Ontari Regulatin 429/07 under the Accessibility
More informationBUPA DENTAL PLAN A P P L I C AT I O N F O R M
BUPA DENTAL PLAN A P P L I C AT I O N F O R M Please cmplete all relevant sectins f the frm in BLOCK CAPITALS and BLACK INK and return it t: Cnsumer Partnerships, FPS Dental, Bupa, Willw Huse, Chertsey
More information