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7 G which there is a reasonably foreseeable risk to customers or to the safety and soundness of a Department from identity theft, including financial, operational, compliance, reputation, or litigation risks. 2. Department - a Cabarrus County department which is a Creditor under 16 CFR §681.2 and which maintains Covered Accounts as that term is defined under this policy or under 16 CFR §681.2. 3. Identity Theft -the illegal use of the identifying information of another person without authority. 4. Notice of Address Discrepancy - a notice sent to a Department by a consumer reporting agency pursuant to 15 U.S.C. 1681c(h)(1), that informs the Department of a substantial difference between the address for the customer that the Department provided to request a consumer report and the address(es) in the consumer reporting agency's file for the customer. 5. Personal Identifying Information -name, address, telephone number, date of birth, Social Security Number, an authenticating password established by a Department for a customer's Covered Account 6. Program - Cabarrus County's Identity Theft Prevention Program 7. Red Flay - a pattern, practice, or specific activity that indicates the possible existence of identity theft. III. IDENTIFICATION OF RELEVANT RED FLAGS Following each of these subheadings is a list of those patterns, practices, and activities considered to be relevant Red Flags under this Program. Some Red Flags may be more relevant to one Deparhnent than they are to another given the nature of the Covered Accounts maintained. The title of each subheading is intended only to categorize the list therein and is not intended to be, in and of itself, a Red Flag under this Program. In identifying these Red Flags, the following factors were considered: the types of covered accounts offered or maintained; the methods provided to open Covered Accounts; the methods provided to access Covered Accounts; and previous experiences with identity theft. In updating this Program, these factors should again be considered with the following additional considerations: identified instances of identity theft that reflect changes in identify theft methods/risks and applicable supervisory guidance from state or federal agencies. A. Notifications or Warnings from a Consumer Reporting AgencY(the Red Flags under this subheading are more relevant for Landfill & Department of Social Services) i. A fraud or active duty alert is included with a consumer report. ii. A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report. iii. A consumer reporting agency provides a notice of address discrepancy iv. A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant for a Covered Account or ' F-12 RM 3/26/2009 2 Attachment number 1 Page 205 of 320