[HISTORY: Adopted by the Board of Supervisors of the Township
of Upper Frederick 4-9-2009 by Res. No. 2009-07. Amendments noted
where applicable.]
The risk to the Township, its employees and customers from data
loss and identity theft is of significant concern to the Township
and can be reduced only through the combined efforts of every employee
and contractor.
A.
The Township adopts this sensitive information policy to help protect
employees, customers, contractors and the Township from damages related
to the loss or misuse of sensitive information.
B.
This policy will:
C.
This policy enables the Township to protect existing customers, reducing
risk from identity fraud, and minimizes potential damage to the Township
from fraudulent new accounts. The program will help the Township:
(1)
Identify risks that signify potentially fraudulent activity within
new or existing covered accounts;
(2)
Detect risks when they occur in covered accounts;
(3)
Respond to risks to determine if fraudulent activity has occurred,
and act if fraud has been attempted or committed; and
(4)
Update the program periodically, including reviewing the accounts
that are covered and the identified risks that are part of the program.
This policy, and the subsequent protection program authorized
by the Township, applies to employees, contractors, consultants, temporary
workers and other workers at the Township, including all personnel
affiliated with third parties.
Sensitive information policy:
A.
Definition of "sensitive information." Sensitive information includes
the following items, whether stored in electronic or printed format:
(4)
Cafeteria plan check requests and associated paperwork.
(7)
Township personnel are encouraged to use common sense judgment in
securing confidential information to the proper extent. Furthermore,
this section should be read in conjunction with the Pennsylvania Open
Records Act and the Township's open records policy. If an employee
is uncertain of the sensitivity of a particular piece of information,
he/she should contact his/her supervisor.
B.
Hard copy distribution. Each employee and contractor performing work
for the Township will comply with the following policies:
(1)
File cabinets, desk drawers, overhead cabinets, and any other storage
space containing documents with sensitive information will be locked
when not in use.
(2)
Storage rooms containing documents with sensitive information and
record retention areas will be locked at the end of each workday or
when unsupervised.
(3)
Desks, workstations, work areas, printers and fax machines, and common
shared, work areas will be cleared of all documents containing sensitive
information when not in use.
(4)
Whiteboards, dry-erase boards, writing tablets, etc., in common shared
work areas will be erased, removed or shredded when not in use.
(5)
When documents containing sensitive information are discarded, they
will be placed inside a locked shred bin or immediately shredded using
a mechanical crosscut or Department of Defense (DOD) approved shredding
device. Locked shred bins are labeled "Confidential Paper Shredding
and Recycling." Township records, however, may only be destroyed in
accordance with the Township's records retention policy.
C.
Electronic distribution. Each employee and contractor performing
work for the Township will comply with the following policies:
(1)
Internally, sensitive information may be transmitted using approved
municipal e-mail. All sensitive information must be encrypted when
stored in an electronic format.
(2)
Any sensitive information sent externally must be encrypted and password
protected and only to approved recipients. Additionally, a statement
such as this should be included in the e-mail:
|
"This message may contain confidential and/or proprietary information
and is intended for the person/entity to whom it was originally addressed.
Any use by others is strictly prohibited."
|
A.
Red flags. Possible sources used for detecting red flags include:
(1)
Alerts, notifications or other warnings received from consumer reporting
agencies or service providers, such as fraud detection services.
(2)
Presentation of suspicious or altered documents.
(3)
Presentation of suspicious, inconsistent or altered personal identifying
information, such as a suspicious address change.
(4)
Attempts to access an account by unauthorized users.
(5)
Unusual use or other suspicious activity related to the covered account.
(6)
Notice from members, victims of identity theft, law enforcement authorities
or other persons regarding possible identity theft in connection with
covered accounts.
B.
Response program.
(1)
Once potentially fraudulent activity is detected, an employee must
act quickly, as a rapid appropriate response can protect customers
and the Township from damages and loss.
(2)
If a transaction is determined to be fraudulent, appropriate actions
must be taken immediately. Actions may include canceling the transaction,
notifying and cooperating with law enforcement, determining the extent
of liability of the Township and notifying the actual customer that
fraud has been attempted.
A.
The policy and procedures established in the program will be reevaluated
to determine whether all aspects of the program are up-to-date and
applicable in the current business environment. Periodic review will
include an assessment of which accounts are covered by the program.
B.
As part of the review, red flags may be revised, replaced or eliminated.
Defining new red flags may also be appropriate. Actions to take in
the event that fraudulent activity is discovered may also require
revision to reduce damage to the Township and its customers.
A.
Board of Supervisors to administer. The Upper Frederick Township
Board of Supervisors shall be responsible for the development, implementation,
oversight and continued administration of the program. The program
shall train staff, as necessary, to effectively implement the program,
and the program shall exercise appropriate and effective oversight
of service provider arrangements.
B.
Oversight of the program. Oversight of the program shall include
assignment of a specific responsibility for implementation of the
program to Jackie Tallon, Township Manager; review of reports prepared
by staff regarding compliance; and approval of material changes to
the program, as necessary.
The Upper Frederick Township Board of Supervisors shall meet
other applicable legal requirements, including, but not limited to,
the requirement to file suspicious activity reports, the requirement
under the Fair Credit Reporting Act (FCRA) regarding the circumstances
in which credit may be extended when the Township detects fraud or
some other alert; the requirement under the FCRA for furnishers of
information to credit bureaus to correct or update inaccurate or incomplete
information and to not report information that is believed inaccurate;
and the prohibitions under the FCRA on the sale, transfer and placement
for collection of certain debts resulting from identity theft.
Township employees who use credit reporting information must
implement policies and procedures designed to enable the employees
to form a reasonable belief that a credit report relates to the customer
about whom it has requested a report when the employee receives a
notice of address discrepancy, which is a red flag. Employees must
compare and verify the information in the credit report with the information
that the Township obtains and uses to verify the customer's identity.
It is the responsibility of the Township to ensure that the
activities of all service providers are conducted, in accordance with
the reasonable policies and procedures designed to detect, prevent
and mitigate the risk of identity theft.
