Red Flag (ID Theft)

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Teachers College Policy Library

Red Flag (ID Theft)

Owner: Controller

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 a
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.