O-2009-3138 Identity Theft Prevention Program

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(1) Identity Theft - fraud committed using the identifying information of another person. (2) Red Flag - pattern, practice, or specific activity that indicates the possible existence of Identity Theft. (3) Creditors - include finance companies, automobile dealers, mortgage brokers, utility companies, and telecommunications companies. Where non-profit and government entities defer payment for goods or services, they, too, are to be considered creditors. According to the Rule, a city is a creditor subject to the Rule requirements. (4) Covered Account - Any account the City offers or maintains primarily for personal, family or household purposes, that involves multiple payments or transactions; and any other account the City offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the City from Identity Theft. By way of example, all the City's accounts that are individual utility service accounts held by customers of the utility whether residential, commercial or industrial are covered by the Rule. (5) Identifying information - Any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including: name, address, telephone number, social security number, date of birth, government issued driver's license or identification number, alien registration number, government passport number, employer or taxpayer identification number, unique electronic identification number, computer's Internet Protocol address, or routing code. c. This policy applies to all City employees and service providers that have access to Covered Accounts maintained by City containing customer's Identifying Information that is submitted in person, by email. by fax, through regular mail, or over the internet. III. IDENTIFICATION OF RED FLAGS a. In order to identify relevant Red Flags, the City 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 City identifies the following red flags, in each of the listed categories: b. Red Flags for Notifications and Warnings from Credit Reporting Agencies (1) Report of fraud accompanying a credit report; (2) Notice or report from a credit agency of a credit freeze on a customer or applicant: S:\Council Agendas - DraJil04272009\FinanceILa P(lrt~ R~d Flag Policy (final for adoption 4 27 (9)doc2