O-2009-3138 Identity Theft Prevention Program

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f. Notify businesses and banks g. Determine that no response is warranted under the particular circumstances VI. PROGRAM UPDATES The Director of Finance will periodically review and update this Program to reflect changes in risks to customers and the soundness of the City from Identity Theft. In doing so, the Director of Finance will consider the City's experiences with Identity Theft situations, changes in Identity Theft methods, changes in Identity Theft detection and prevention methods, and changes in the City's business arrangements with other entities. After considering these factors, the Director of Finance will determine whether changes to the Program, including the listing of Red Flags, are warranted. If warranted, the Director of Finance will update the Program or present the City Council with his or her recommended changes and the City Council will make a determination of whether to accept, modify, or reject those changes to the Program. VII. PROGRAM ADMINISTRATION. a. Oversight. Responsibility for developing, implementing and updating this Program lies with the Director of Finance or their designee. This person will be responsible for the Program administration, for ensuring appropriate training of all employees in a position to have access to or the use of Identifying Information, for reviewing any staff reports regarding the detection of Red Flags and the steps for 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. b. Staff Training and Reports. Finance Department staff responsible for implementing the Program shall be trained either by or under the direction of the Director of Finance in the detection of Red Flags, and the responsive steps to be taken when a Red Flag is detected. c. Service Provider Arrangements. In the event the City engages a service provider to perform an activity in connection with one or more accounts, the City will take the following steps to ensure the service provider perfoffi1s its activity in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of Identity Theft. (1) Require, by contract, that service providers have such policies and procedures in place; and (2) Require, by contract, that service providers review the City's Progran1 and report any Red Flags to the Director of Finance. SICouncil Agendas - Draft\04272009IFinanceILa Porte Red Flag Policy (fInal for adoption 4 27 (9).doc7