The Village of Carthage ("utility") developed this identity
theft prevention program ("program") pursuant to the Federal Trade
Commission's Red Flags Rule ("Rule"), which implements Section 114
of the Fair and Accurate Credit Transactions Act of 2003, 16 C.F.R.
§ 681.2. This program was developed with oversight and approval
of the Village of Carthage Board of Trustees. After consideration
of the size and complexity of the utility's operations and account
systems, and the nature and scope of the utility's activities, the
Board of Trustees determined that this program was appropriate for
the Village of Carthage and therefore approved this program on May
18, 2009.
In order to identify relevant red flags, the utility considers
the types of accounts that it offers and maintains, the methods it
provides to open its accounts, the methods it provides to access its
accounts, and its previous experiences with identity theft. The utility
identifies the following red flags, in each of the listed categories:
A. Suspicious documents red flags:
(1)
Identification document or card that appears to be forged, altered
or inauthentic.
(2)
Identification document or card on which a person's photograph
or physical description is not consistent with the person presenting
the document.
(3)
Other document with information that is not consistent with
existing customer information (such as if a person's signature on
a check appears forged).
(4)
Application for service that appears to have been altered or
forged.
B. Suspicious personal identifying information red flags:
(1)
Identifying information presented that is inconsistent with
other information the customer provides (example: inconsistent birth
dates).
(2)
Identifying information presented that is inconsistent with
other sources.
(3)
Identifying information presented that is the same as information
shown on other applications that were found to be fraudulent.
(4)
Identifying information presented that is consistent with fraudulent
activity (such as an invalid phone number or fictitious billing address).
(5)
An address or phone number presented that is the same as that
of another person.
(6)
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.)
(7)
A person's identifying information is not consistent with the
information that is on file for the customer.
C. Suspicious account activity or unusual use of account red flags:
(1)
Change of address for an account followed by a request to change
the account holder's name.
(2)
Payments stop on an otherwise consistently up-to-date account.
(3)
Account used in a way that is not consistent with prior use
(example: very high activity).
(4)
Mail sent to the account holder is repeatedly returned as undeliverable.
(5)
Notice to the utility that a customer is not receiving mail
sent by the utility.
(6)
Notice to the utility that an account has unauthorized activity.
(7)
Breach in the utility's computer system security.
(8)
Unauthorized access to or use of customer account information.
D. Alerts from others red flags:
(1)
Notice to the utility 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.
In the event utility personnel detect any identified red flags,
such personnel shall take one or more of the following steps, depending
on the degree of risk posed by the red flag:
A. Prevent and mitigate.
(1)
Continue to monitor an account for evidence of identity theft.
(3)
Change any passwords or other security devices that permit access
to accounts.
(5)
Close an existing account.
(6)
Reopen an account with a new number.
(7)
Notify the program administrator for determination of the appropriate
step(s) to take.
(9)
Determine that no response is warranted under the particular
circumstances.
B. Protect customer identifying information. In order to further prevent
the likelihood of identity theft occurring with respect to utility
accounts, the utility will take the following steps with respect to
its internal operating procedures to protect customer identifying
information:
(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 customer information.
(3)
Ensure that office computers are password-protected and that
computer screens lock after a set period of time.
(4)
Keep offices clear of papers containing customer information.
(5)
Ensure computer virus protection is up-to-date.
(6)
Require and keep only the kinds of customer information that
are necessary for utility purposes.
This program will be periodically reviewed and updated to reflect
changes in risks to customers and the soundness of the utility from
identity theft. At least every year the program administrator will
consider the utility's experiences with identity theft situation,
changes in identity theft methods, changes in identity theft detection
and prevention methods, changes in types of accounts the utility maintains
and changes in the utility's business arrangements with other entities.
After considering these factors, the program administrator will determine
whether changes to the program, including the listing of red flags,
are warranted. If warranted, the program administrator will update
the program or present the Board of Trustees with his or her recommended
changes, and the Board of Trustees will make a determination of whether
to accept, modify or reject those changes to the program.