O-2009-3138 Identity Theft Prevention Program

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(8) A person's identifying information is not consistent with the information that is on file for the customer. e. Red Flags for Suspicious Account Activity or Unusual Use of Account (1) Change of address for an account followed by a request to change the account holder's name; (2) Payments stop on an otherwise consistently up-to-date account; (3) Account used in a way that is not consistent with prior use (example: very high activity); (4) Mail sent to the account holder is repeatedly returned as undeliverable; (5) Notice to the City that a customer is not receiving mail sent by the City; (6) Notice to the City that an account has unauthorized activity; (7) Breach in the City's computer system security; and (8) Unauthorized access to or use of customer account information. f. Red Flag Alerts from Others. Notice to the City 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. IV. DETECTING RED FLAGS a. Detection of New Accounts. In order to detect any of the Red Flags identified above associated with the opening of a new account, City personnel will take the following steps to obtain and verify the identity of the person opening the account: (1) Require certain identifying information such as name, residential or business address, driver's license or other identification; (2) Request additional documentation to establish identity if necessary: (3) Independently contact the customer. c. Detection of Existing Accounts. In order to detect any of the Red Flags identified above for an existing account. City personnel will take the following steps to monitor transactions with an account: S:\Council Agendas - Drati\04272009\Financc\La Parle Red Flag Policy (final for adoption 4 27 (9).doc4