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Teachers College Policy Library
Red Flag (ID Theft)
URL: http://www.tc.columbia.edu/policylibrary/Red Flag (ID Theft)
A. PROGRAM ADOPTION.
Teachers College, Columbia University (the "College") has developed this Identity Theft Prevention Program ("Program") pursuant to the Federal Trade Commission's ("FTC") Red Flags Rule, which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. This Program was developed with oversight and approval of the College's Board ofTrustees. After consideration of the size and complexity of the College's operations and account systems, and the nature and scope of the College's activities, the Trustees determined that this Program was appropriate for the College, and therefore approved this Program_, 2010.
B. DEFINITIONS AND PROGRAM
1. Red Flags Rule Definitions Used in this Program
a. "Identity Theft" is a "fraud committed or attempted using the identifying information of another person without authority."
b. A "Red Flag" is a "pattern, practice, or specific activity that indicates the possible existence of Identity Theft."
c. A "Covered Account" includes all individual accounts or loans that are administered by the College.
d. "Program Administrator" is the individual designated with primary responsibility for oversight of the program. See Section VI below.
e. "Identifying information" is "any name or number that may be used, alone or in conjunction with any other information, to identify a specific person," including: name, address, telephone number, social security number, date of birth, government issued driver's license or identification number, alien registration number, government passport number, employer or taxpayer identification number, individual identification number, computer's Internet Protocol address, or routing code.
2. Fulfilling Requirements of the Red Flags Rule
C. Under the Red Flags Rule, the College is required to establish an "Identity Theft Prevention Program" tailored to its size, complexity and the nature of its operation. Each program must contain reasonable policies and procedures to:
1. Identify relevant Red Flags for new and existing covered accounts and incorporate those Red Flags into the Program;
2. Detect Red Flags that have been incorporated into the Program;
3. Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity Theft; and
4. Ensure the Program is updated periodically to reflect changes in risks to individuals or to the safety and soundness of the individual from Identity Theft.
D. IDENTIFICATION OF RED FLAGS
1. In order to identify relevant Red Flags, the College considers the types of accounts that it offers and maintains methods it provides to open its accounts, methods it provides to access its accounts, and its previous experiences with Identity Theft. The College 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) 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 individual provides (example: inconsistent birth dates);
2) Identifying information presented that is inconsistent with other sources of information and which raises suspicion of identity theft (example: inconsistent undergraduate institutions during the same time period);
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) Social security number presented that is the same as one known to have been given by another individual;
6) An address or phone number presented that is the same as that of another person who is not a family member, roommate or other documented relation;
7) A person fails to provide complete personal identifying information on an application when reminded to do so; and
c. Suspicious Covered Account Activity or Unusual Use of Account Red Flags
1) Change of address for an account followed by a request to change the individual's name;
2) Mail sent to the individual is repeatedly returned as undeliverable;
3) Notice to The College that an account has unauthorized activity;
4) Breach in The College's computer system security; and
5) Unauthorized access to or use of individual account information.
d. Alerts from Others Red Flag: Notice to the College from an individual, Identity Theft victim, law enforcement or other person that the College has opened or is maintaining a fraudulent account for a person engaged in Identity Theft.
E. DETECTING RED FLAGS
1. Initial Hire and Enrollment. In order to detect Red Flags identified above associated with the enrollment of a individual, College personnel will take the following steps to obtain and verify the identity of the person opening the account:
a. Require certain identifying information such as name, previous academic records, home address or other identification; and
b. Verify the individual's identity at time of issuance of individual identification card (review of driver's license or other government issued photo identification).
2. Existing Accounts. In order to detect Red Flags identified above for an existing Covered Account, College personnel will take the following steps to monitor transactions on an account:
a. Verify in person the identification of individuals if they request information related to student records, personal information and financial and banking information;
b. Verify the validity of requests to change or add new addresses by email and provide the individual a reasonable means of promptly reporting incorrect billing address changes.
3. Consumer ("Credit") Report Requests. In order to detect any of the Red Flags identified above for an employment or volunteer position for which a credit or background report is sought, College personnel will take the following steps to assist in identifying address discrepancies:
a. Require written verification from any applicant that the address provided by the applicant is accurate at the time the request for the credit report is made to the consumer reporting agency; and
b. In the event that notice of an address discrepancy is received, verify that the credit report pertains to the applicant for whom the requested report was made and report to the consumer reporting agency an address for the applicant that the College has reasonably confirmed is accurate.
F. PREVENTING AND MITIGATING IDENTITY THEFT
1. In the event University personnel detect any identified Red Flags, such personnel may take one or more of the following steps, depending on the degree of risk posed by the Red Flag:
a. Prevent and Mitigate
1) Contact the individual or applicant whose data maybe compromised;
2) Change any passwords or other security devices that permit access to Covered Accounts;
3) Not open a new Covered Account;
4) Provide the individual with a new individual identification number;
5) Notify the Program Administrator for determination of the appropriate step( s) to take;
6) Notify law enforcement;
7) Determine that no response is warranted under the particular circumstances.
2. Protect Individual Identifying Information. In order to further prevent the likelihood of Identity Theft occurring with respect to Covered Accounts, the College will take the following steps with respect to its internal operating procedures to protect individual identifying information:
a. Ensure that its website is secure or provide clear notice that the website is not secure; Ensure computer virus protection is up to date; Ensure that office computers with access to Covered Account information are password protected;
b. Ensure complete and secure destruction of paper documents and computer files containing individual account information when a decision has been made to no longer maintain such information;
c. A void use of social security numbers (use T number); and
d. Require and keep only the kinds of individual information that are necessary for College purposes.
G. PROGRAM ADMINISTRATION
1. Oversight. Responsibility for developing, implementing and updating this Program lies with an Identity Theft Committee ("Committee") for the College. The Committee is headed by a Program Administrator who shall be appointed by the Vice President for Finance and Administration. Two or more other individuals appointed by the Vice President for Finance and Administration comprise the remainder of the committee. The Program Administrator will be responsible for ensuring appropriate training of College staff on the Program, for reviewing any staff reports regarding the detection of Red Flags and the steps for preventing and mitigating Identity Theft, determining which steps of prevention and mitigation should be taken in particular circumstances and considering periodic changes to the Program.
2. Staff Training and Reports. College staff responsible for implementing the Program shall be trained either by or under the direction of the Program Administrator in the detection of Red Flags and the responsive
steps to be taken when a Red Flag is detected. College staff shall be trained, as necessary, to effectively implement the Program. College employees are expected to notify the Program Administrator once they
become aware of an incident ofldentity Theft or of the College's failure to comply with this Program. At least annually or as otherwise requested by the Program Administrator, College staff responsible for development,
implementation, and administration of the Program shall report to the Program Administrator on compliance with this Program. The report should address such issues as effectiveness of the policies and procedures
in addressing the risk of identity theft in connection with the opening and maintenance of Covered Accounts, service provider arrangements, significant incidents involving identity theft and management's response, and recommendations for changes to the Program.
3. Service Provider Arrangements. In the event the College engages a service provider to perform an activity in connection with one or more Covered Accounts, the College will take the following steps to ensure the
service provider performs its activity in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of Identity Theft.
a. Require, by contract, that service providers have such policies and procedures in place; and
b. Require, by contract, that service providers review the College's Program and report any Red Flags to the Program Administrator or the College employee with primary oversight of the service provider relationship.
4. Non-disclosure of Specific Practices. For the effectiveness of this Identity Theft Prevention Program, knowledge about specific Red Flag identification, detection, mitigation and prevention practices may need to
be limited to the Committee who developed this Program and to those employees with a need to know them. Any documents that may have been produced or are produced in order to develop or implement this program
that list or describe such specific practices and the information those documents contain are considered "confidential" and should not be shared with other College employees or the public. The Program Administrator shall inform the Committee and those employees with a need to know the information of those documents or specific practices which should be maintained in a confidential manner.
5. Program Updates. The Committee will periodically review and update this Program to reflect changes in risks to individuals and the soundness of the College from Identity Theft. In doing so, the Committee will consider the College's experiences with Identity Theft situations, changes in Identity Theft methods, changes in Identity Theft detection and prevention methods, and changes in the College'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 Committee will update the Program.
Responsible Office: Controller
Effective Date: 2010
Last Updated: January 2015