This program is established in order to comply with Wisconsin Statutes Chapter 19, Subchapter IV, and to the extent applicable the Federal Fair and Accurate Credit Transactions Act of 2003. This program is intended to establish reasonable policies and procedures to:
A.
Develop rules of conduct for Town employees who are involved in collecting, maintaining, using, providing access to, sharing or archiving personally identifiable information;
B.
Ensure that Town employees know their duties and responsibilities relating to protecting personal privacy, including applicable state and federal laws;
C.
Identify relevant indications that an identity theft is being perpetrated ("red flags") for new and existing covered accounts and incorporate those red flags into the program;
D.
Detect red flags that have been incorporated into the program;
E.
Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
F.
Update the program periodically to reflect changes in risks to customers or to the safety and soundness of the Town from identity theft.