Privacy Issues in the Community College Workplace

A PPENDIX P

S AMPLE I DENTITY T HEFT P REVENTION P OLICY

I. T HE P URPOSE OF THE I DENTITY T HEFT P REVENTION P ROGRAM The purpose of this Identity Theft Prevention Program (ITPP) is to control reasonably foreseeable risks to persons from identity theft. Identity theft results in billions of dollars in losses each year to individuals and businesses. Our district is required to provide for the identification, detection, and response to patterns, practices, or specific activities (“Red Flags”) that could indicate identity theft. This is because our district is a “creditor” with “covered accounts.” “Identity theft” is a fraud attempted or committed using identifying information of another person without authority. A “creditor” includes government entities who defer payment for goods or services (for example, payment for utilities, or payment plans for parking tickets). “Deferring payments” refers to postponing payments to a future date and/or installment payments on fines or costs. A “covered account” includes one that involves multiple payments or transactions. For example, covered accounts include utility accounts. “Person” means any individual who is receiving goods and/or services from our district and is making payments on a deferred basis for said goods and/or services. Detection or discovery of a “Red Flag” implicates the need to take action under this ITPP to help prevent, detect, and correct identity theft. II. D EFINITIONS

III. D ETECTING “R ED F LAGS ” F OR P OTENTIAL I DENTITY T HEFT

A. Risk Factors for Identifying “Red Flags” Our district will consider the following factors in identifying relevant “Red Flags:”

(1) the types of covered accounts our district offers or maintains;

(2) the methods our district provides to open our district’s covered accounts;

(3) the methods our district provides to access our district’s covered accounts; and

Privacy Issues in the Community College Workplace ©2019 (c) Liebert Cassidy Whitmore 224