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1 <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />g. Other appropriate action to prevent or mitigate identity theft; or <br />h. Determining that no response is warranted under the particular <br />circumstances. <br />ii. Appropriate responses for the detection of a Red Flag associated with the <br />opening of a new Covered Account may include the following: <br />a. Requesting additional identifying information from the applicant; <br />b. Not opening a new Covered Account; <br />c. Notifying law enforcement; <br />d. Other appropriate action to prevent or mitigate identity theft; or <br />e. Determining that no response is warranted under the particular <br />circumstances. <br />B. Ag ravating Factors <br />i. In deciding the appropriate response, the Department shall consider <br />aggravating factors that may heighten the risk of identity theft, such as: <br />a. A data security incident that results in unauthorized access to a customer's <br />Covered Account records held by the Department, or <br />b. A customer has provided notice to the Department that he or she has been <br />a victim of identity theft. <br />VI. ADMINISTERING AND UPDATING THIS PROGRAM <br />A. Periodic Updates <br />This policy will be periodically updated to reflect changes in risks to customers or to <br />the safety and soundness of Department(s) from identity theft, based on factors such <br />as: <br />Experiences with identity theft <br />a. Changes in methods of identity theft <br />b. Changes in methods to detect, prevent, and mitigate identity theft; <br />c. Changes in the types of covered accounts offered or maintained <br />d. Changes in an applicable service provider arrangement <br />B. Oversight <br />The Safety & Risk Manager will be responsible for overseeing this program. <br />However, he or she will report findings to the County and Deputy Managers. He will <br />be responsible for, among other things: <br />a. Assigning specific responsibility for the Program's implementation; <br />b. Reviewing reports prepared by Department staff regarding Department's <br />compliance with 16 C.F.R. §681.2.; and <br />c. Approving material changes to the Program as necessary to address <br />changing identity theft risks. <br />F-12 <br />RM 3/26/2009 6 <br />Attachment number 1 <br />Page 209 of 320 <br />