The identity theft prevention policy set forth in this article,
establishing rules and procedures to detect, prevent and mitigate
identity theft, is hereby approved.
The President and Village Board appoint the Village Administrator
as the program administrator of the Identity Theft Prevention Program
and chairperson of the Identity Theft Prevention Committee.
Identity theft has become the number one consumer fraud issue
in the country. In 2007, more than 10,000 identity theft complaints
were filed with the Federal Trade Commission (FTC) by Illinois residents.
The Village of Coal City recognizes that the risk to the Village,
its employees, residents, and customers from data loss and identity
theft is a significant concern to the Village, which this Identity
Theft Prevention Program ("program") seeks to address.
The Village developed the program in an effort to battle identity
theft. The program was developed with oversight and approval of the
President and Village Board. After consideration of the size and complexity
of the Village's operations and customer account systems, and the
nature and scope of the Village's activities, the President and Village
Board determined that this program was appropriate for the Village,
and therefore approved the program on April 27, 2008.
For the purpose of this article, the following definitions shall
apply unless the context clearly indicates or requires a different
meaning:
COVERED ACCOUNT
A.
An account that the Village offers or maintains, primarily for
personal, family, or household purposes, that involves or is designed
to permit multiple payments or transactions, such as a utility account;
and
B.
Any other account that the Village offers or maintains for which
there is a reasonably foreseeable risk to customers or to the safety
and soundness of the Village, including financial, operational, compliance,
reputation, or litigation risks.
CREDIT
The right granted by a creditor to a debtor to defer payment
of debt or to incur debts and defer its payment or to purchase property
or services and defer payment therefor.
CREDITOR
Any person who regularly extends, renews, or continues credit;
any person who regularly arranges for the extension, renewal, or continuation
of credit; or any assignee of an original creditor who participates
in the decision to extend, renew, or continue credit, including utility
companies.
CUSTOMER
A person that has a covered account with a creditor.
IDENTITY THEFT
A fraud committed or attempted using identifying information
of another person without authority.
PERSON
A natural person, a corporation, government or governmental
subdivision or agency, trust, estate, partnership, cooperative, or
association.
RED FLAG
A pattern, practice, or specific activity that indicates
the possible existence of identity theft.
SENSITIVE INFORMATION
Any name or number that may be used, alone or in conjunction
with any other information, to identify a specific person, including,
but not limited to, a person's credit card account information, debit
card information, bank account information, driver's license information,
social security number, mother's birth name, date of birth, electronic
identification number, computer internet protocol address, and routing
code.
In order to identify relevant red flags, the Village 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 Village
identifies the following red flags, in the following listed categories:
A. Notifications and warnings from credit reporting agencies. Red flags:
(1) Report of fraud accompanying a credit report;
(2) Notice or report from a credit agency of a credit freeze on a customer
or applicant;
(3) Notice or report from a credit agency of an active-duty alert for
an applicant; and
(4) Indication from a credit report of activity that is inconsistent
with a customer's usual pattern or activity.
B. Suspicious documents. Red flags:
(1) Identification document or card that appears to be forged, altered
or otherwise 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 documentation with information that is not consistent with
existing customer information (e.g., a person's signature on a check
appears forged); and
(4) Application for service that appears to have been altered or forged.
C. Suspicious personal identifying information. Red flags:
(1) Identifying information presented that is inconsistent with other
information the customer provides (e.g., inconsistent birth dates);
(2) Identifying information presented that is inconsistent with other
sources of information (e.g., an address not matching an address on
a credit report);
(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 (e.g., an invalid phone number or an answering service, or
fictitious billing address, mail drop or prison);
(5) Social security number presented that is the same as one given by
another customer;
(6) An address or phone number presented that is the same as that of
another person;
(7) A person fails to provide complete personal identifying information
on an application when reminded to do so; and
(8) A person's identifying information is not consistent with the information
that is on file for the customer.
D. 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 (e.g.,
very high activity);
(4) Mail sent to the account holder is repeatedly returned as undeliverable;
(5) Notice to the Village that a customer is not receiving mail sent
by the Village;
(6) Notice to the Village that an account has unauthorized activity;
(7) Breach in the Village's computer system security; and
(8) Unauthorized access to or use of customer account information.
E. Alerts from others. Red flag:
(1) Notice to the Village 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.
This program will be periodically reviewed and updated to try
and reflect changes in risks to customers and the soundness of the
Village from identity theft. At least once a year, the program administrator
will consider the Village's experiences with identity theft, changes
in identity theft methods, changes in identity theft detection and
prevention methods, changes in types of accounts the Village maintains
and changes in the Village'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 President and Village Board with his or
her recommended changes and the President and Village Board will make
a determination of whether to accept, modify or reject those changes
to the program.