The risk to the municipality, its employees and customers from
data loss and identity theft is of significant concern to the municipality
and can be reduced only through the combined efforts of every employee
and contractor.
This policy and protection program applies to employees, contractors,
consultants, temporary workers and other workers at the municipality,
including all personnel affiliated with third parties.
If the municipality maintains certain covered accounts pursuant
to federal legislation, the municipality may include the additional
program details:
A. Covered accounts. A covered account includes any account that involves
or is designed to permit multiple payments or transactions. Every
new and existing customer account that meets the following criteria
is covered by this program:
(1) Business, personal and household accounts for which there is a reasonably
foreseeable risk of identity theft; or
(2) Business, personal and household accounts for which there is a reasonably
foreseeable risk to the safety or soundness of the municipality from
identity theft, including financial, operational, compliance, reputation
or litigation risks.
B. Red flags.
(1) The following red flags are potential indicators of fraud. Any time
a red flag, or a situation closely resembling a red flag, is apparent,
it should be investigated for verification.
(a)
Alerts, notifications or warnings from a consumer reporting
agency;
(b)
A fraud or active duty alert included with a consumer report;
(c)
A notice of credit freeze from a consumer reporting agency in
response to a request for a consumer report; or
(d)
A notice of address discrepancy from a consumer reporting agency.
[Amended 6-7-2021 by Ord.
No. 764]
(2) Red flags also include consumer reports that indicate a pattern of
activity inconsistent with the history and usual pattern of activity
of an applicant or customer, such as:
(a)
A recent and significant increase in the volume of inquiries;
(b)
An unusual number of recently established credit relationships;
(c)
A material change in the use of credit, especially with respect
to recently established credit relationships; or
(d)
An account that was closed for a cause or identified for abuse
of account privileges by a financial institution or creditor.
C. Suspicious documents.
(1) Documents provided for identification that appear to have been altered
or forged.
(2) The photograph or physical description on the identification is not
consistent with the appearance of the applicant or customer presenting
the identification.
(3) Other information on the identification is not consistent with information
provided by the person opening a new covered account or customer presenting
the identification.
(4) Other information on the identification is not consistent with readily
accessible information that is on file with the municipality, such
as a signature card or a recent check.
(5) An application appears to have been altered or forged or gives the
appearance of having been destroyed and reassembled.
D. Suspicious personal identifying information.
(1) Personal identifying information provided is inconsistent when compared
against external information sources used by the municipality. For
example:
(a)
The address does not match any address in the consumer report;
(b)
The social security number (SSN) has not been issued or is listed
on the Social Security Administration's death master file; or
(c)
Personal identifying information provided by the customer is
not consistent with other personal identifying information provided
by the customer. For example, there is a lack of correlation between
the SSN range and date of birth.
(2) Personal identifying information provided is associated with known
fraudulent activity as indicated by internal or third-party sources
used by the municipality. For example, the address on an application
is the same as the address provided on a fraudulent application.
(3) Personal identifying information provided is of a type commonly associated
with fraudulent activity as indicated by internal or third-party sources
used by the municipality. For example:
(a)
The address on an application is fictitious, a mail drop or
a prison; or
(b)
The phone number is invalid or is associated with a pager or
answering service.
(4) The SSN provided is the same as that submitted by other persons opening
an account or other customers.
(5) The address or telephone number provided is the same as or similar
to the address or telephone number submitted by an unusually large
number of other customers or other persons opening accounts.
(6) The customer or the person opening the covered account fails to provide
all required personal identifying information on an application or
in response to notification that the application is incomplete.
(7) Personal identifying information provided is not consistent with
personal identifying information that is on file with the municipality.
(8) When using security questions (mother's maiden name, pet's name,
etc.), the person opening the covered account or the customer cannot
provide authenticating information beyond that which generally would
be available from a wallet or consumer report.
E. Unusual use of, or suspicious activity related to, the covered account.
(1) Shortly following the notice of a change of address for a covered
account, the municipality receives a request for new, additional or
replacement goods or services, or for the addition of authorized users
on the account.
(2) A new revolving credit account is used in a manner commonly associated
with known patterns of fraud patterns. For example, the customer fails
to make the first payment or makes an initial payment but no subsequent
payments.
(3) A covered account is used in a manner that is not consistent with
established patterns of activity on the account. There is, for example:
(a)
Nonpayment when there is no history of late or missed payments;
(b)
A material change in purchasing or usage patterns.
(4) A covered account that has been inactive for a reasonably lengthy
period of time is used (taking into consideration the type of account,
the expected pattern of usage and other relevant factors).
(5) Mail sent to the customer is returned repeatedly as undeliverable
although transactions continue to be conducted in connection with
the customer's covered account.
(6) The municipality is notified that the customer is not receiving paper
account statements.
(7) The municipality is notified of unauthorized charges or transactions
in connection with a customer's covered account.
(8) The municipality receives notice from customers, victims of identity
theft, law enforcement authorities or other persons regarding possible
identity theft in connection with covered accounts held by the municipality.
(9) The municipality is notified by a customer, a victim of identity
theft, a law enforcement authority or any other person that it has
opened a fraudulent account for a person engaged in identity theft.
This policy will take effect immediately, on October 20, 2008.