Identity Theft Prevention (“Red Flag”) Program

Responsible Office or Person: Business Office

Related Law & Policy: Covered Accounts

Scope

This policy covers the personal and private information of Carroll University constituents, including faculty, staff, students, vendors, volunteers and donors.
 

Policy Statement

This policy implements an Identity Theft Prevention Program (the “Program”) at Carroll University, pursuant to the Federal Trade Commission’s Red Flags Rule under section 114 and 315 of the Fair and Accurate Credit Transactions Act, which amended the Fair Credit Reporting Act.  This policy and its related procedures are determined to be appropriate to the size and complexity of the university’s operations and the nature and scope of its activities.
 
The purpose of the Program is to detect, prevent and mitigate identity theft in connection with conducting University business.  This policy and related procedures are designed to identify relevant red flags and incorporate them into the Program; detect red flags that are part of the Program; respond appropriately to any red flags that are detected; and ensure the Program is updated periodically to address changing risks.
 

Definitions

Pursuant to the Red Flag regulations at 16 C. F. R. § 681.2, the following definitions shall apply to this Program:
 
Covered Accounts:
 
1. Any account the University offers or maintains primarily for personal, family or household purposes, that permits multiple payments or transactions.
 
2. Any other account the University offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the University from Identity Theft, including financial, operational, compliance, reputation, or litigation risks.
 
Credit: The right granted by a creditor to a debtor to defer payment of debt or to incur debt and defer its payment or to purchase property or services and defer payment therefore.
 
Creditor: An entity that regularly extends, renews, or continues credit.
 
Customer: Any person with a covered account with a creditor.
 
Identifying information: Any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including: Identify theft: A fraud committed using the identifying information of another person without authority.
 
Red Flag: A pattern, practice, or specific activity that indicates the possible existence of identity theft.

Compliance

Carroll University is required to establish an Identity Theft Prevention Program (the “Program”) to detect, prevent, and mitigate identity theft. The Program shall include reasonable policies and procedures to:
  1. Identify relevant Red Flags for covered accounts it offers or maintains and incorporate those Red Flags into the Program.
  2. Detect and record Red Flags that have been incorporated into the Program. 
  3. Respond appropriately to any Red Flags that are detected to prevent and mitigate identity theft.
  4. Ensure the Program is updated periodically to reflect changes in identity theft risks to customers and to the safety and soundness of the University in its role as creditor.
  5. Administer the Program
The Program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.

Responsible University Official
The Vice President for Finance and Administration, or her senior management designee, will serve as Program Administrator. The Program Administrator shall exercise appropriate and effective oversight over the Program and the senior management designee shall report regularly to the Vice President of Finance and Administration.
 
Program Administration, Maintenance and Responsibility
The Program Administrator and her designee are responsible for developing, implementing and updating the Program throughout the University system. The Program Administrator and her designee will be responsible for ensuring appropriate training of University staff on the Program, for reviewing any staff reports regarding the detection of Red Flags and the steps for identifying, preventing and mitigating identity theft, determining which steps of prevention and mitigation should be taken in particular circumstances and considering periodic changes to the Program.
 
The Program will be annually reviewed and updated to reflect changes in identity theft risks and technological changes. The Program Administrator will consider the University’s experiences with identity theft, changes in identity theft methods; changes in identity theft detection, mitigation and prevention methods; changes in types of accounts the University maintains; changes in the University’s business arrangements with other entities, and any changes in legal requirements in the area of identity theft. After considering these factors, the Program Administrator will determine whether changes to the Program, including the listing of Red Flags, are warranted.
 
The Program Administrator shall confer with all appropriate University personnel as necessary to ensure compliance with the Program. The Program Administrator shall present any recommended changes to the Vice President of Finance and Administration for approval. The approval of the Vice President of Finance and Administration shall be sufficient to make changes to the Program.
 
Identification of Relevant Red Flags
In order to identify relevant Red Flags, the University considers the types of accounts that it offers and maintains, the methods it provides to open its accounts, the methods it provides to access its accounts, and its previous experiences with Identity Theft. The following are relevant Red Flags, in each of the listed categories, which University personnel should be aware of and diligent in monitoring for:
  1. Notifications and Warnings from Credit Reporting Agencies
    • Report of fraud accompanying a credit report;
    • Notice or report from a credit agency of a credit freeze on a customer or applicant;
    • Notice or report from a credit agency of an active duty alert for an applicant; and
    • Indication from a credit report of activity that is inconsistent with a customer’s usual pattern or activity.
  2. Suspicious Documents
    • Identification document or card that appears to be forged, altered or inauthentic;
    • Identification document or card on which a person’s photograph or physical description is not consistent with the person presenting the document;
    • Other document with information that is not consistent with existing customer information (such as if a person’s signature on a check appears forged); and
    • Application for service that appears to have been altered or forged.
  3. Suspicious Personal Identifying Information
    • Identifying information presented that is inconsistent with other information the customer provides (example: inconsistent birth dates);
    • Identifying information presented that is inconsistent with other sources of information (for instance, an address not matching an address on a credit report);
    • Identifying information presented that is the same as information shown on other applications that were found to be fraudulent;
    • Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address);
    • Social security number presented that is the same as one given by another customer;
    • An address or phone number presented that is the same as that of another person;
    • A person fails to provide complete personal identifying information on an application when reminded to do so (however, by law social security numbers must not be required); and
    • A person’s identifying information is not consistent with the information that is on file for the customer.
  4. Suspicious Account Activity or Unusual Use of Account
    • Change of address for an account followed by a request to change the account holder's name;
    • Payments stop on an otherwise consistently up-to-date account;
    • Account used in a way that is not consistent with prior use (example: very high activity);
    • Mail sent to the account holder is repeatedly returned as undeliverable; Notice to the University that a customer is not receiving mail sent by the University;
    • Notice to the University that an account has unauthorized activity;
    • Breach in the University’s computer system security; and
    • Unauthorized access to or use of customer account information.
  5. Alerts from Others
    • Notice to the University from a customer, identity theft victim, law enforcement or other person that it has opened or is maintaining a fraudulent account for a person engaged in Identity Theft.
 
Detection of Red Flags
The Program Administrator and her designee will develop and implement specific methods and protocols appropriate to meet the requirements of this Program.
  1. New Accounts
In order to detect any of the Red Flags identified above associated with the opening of a new account, University personnel will take appropriate steps to obtain and verify the identity of the person opening the account.  Such steps may include the following:
  1. Existing Accounts
In order to detect any of the Red Flags identified above for an existing account, University personnel will take appropriate steps to monitor transactions with an account.  Such steps may include the following:  
Responding to Red Flags and Mitigating Identity Theft
In the event University personnel detect any identified Red Flags, such personnel shall take appropriate steps to respond and mitigate identity theft depending on the nature and degree of risk posed by the Red Flag, including but not limited to the following examples:
  1. Monitor a covered account for evidence of identity theft.
  2. Contact the customer.
  3. Change any passwords, security codes or other security devices that permit access to a covered account.
  4. Reopen a covered account with a new account number.
  5. Not open a new covered account.
  6. Close an existing covered account.
  7. Notify law enforcement.
  8. File or assist in filing a Suspicious Activities Report (SAR).
  9. Determine no response is warranted under the particular circumstances.
 
Protecting Identifying Information
In order to further prevent the likelihood of Identity Theft occurring with respect to Covered Accounts, The University will take the following steps with respect to its internal operating procedures to protect identifying information:
  1. Ensure that its website is secure or provide clear notice that the website is not secure.
  2. Ensure complete and secure destruction of paper documents and computer files containing account information when a decision has been made to no longer maintain such information.
  3. Ensure that office computers with access to Covered Account information are password protected.
  4. Use of Social Security Numbers only when necessary.
  5. Ensure computer virus protection is up to date.
  6. Require and keep only the kinds of information that are necessary for University purposes.
  7. File cabinets, desk drawers, overhead cabinets, and other storage spaces containing sensitive information will be locked when not in use. 
  8. Desks, workstations, work areas, printers, fax machines, and common shared work areas will be cleared of documents containing sensitive information.
  9. Whiteboards, dry erase boards, writing tablets, etc., in common shared areas will be erased, removed or shredded when not in use.             
 
Service Provider Arrangements
In the event the University engages a service provider to perform an activity in connection with one or more accounts, the University will take appropriate steps to ensure the service provider performs its activity in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft. Such steps may include the following:
  1. Reviewing a copy of that service provider’s identity theft policies and procedures;
  2. Require, by contract, that service providers have such policies and procedures in place; and
  3. Require, by contract, that service providers review the University's Program and report any Red Flags to the Program Administrator.
 
Staff Training and Reporting
University personnel responsible for implementing the Program shall be trained under the direction of the Program Administrator and her designee, as appropriate, in the detection of Red Flags, and the responsive steps to be taken when a Red Flag is detected. Appropriate staff shall provide reports to the Program Administrator on incidents of identity theft, the effectiveness of the Program and the University’s compliance with the Program.
 
 

 

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