Identity Theft Prevention (“Red Flag”) Program

Responsible Office or Person: Business Office

Related Law & Policy: Covered Accounts

• 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
• School ID card
• Birth certificate
• Insurance card
• Health records
• Transcripts

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

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.

1. New Accounts

• Require certain identifying information such as name, date of birth, residential or business address, driver's license or other identification;
• Verify the customer's identity (for instance, review a driver's license or other identification card);
• Independently contact the customer.

2. Existing Accounts

• Verify the identification of customers if they request information (in person, via telephone, via facsimile, via email);
• Verify the validity of requests to change billing addresses; and
• Verify changes in banking information given for billing and payment purposes.

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.

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.             

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.