CP084 (Identity Theft Prevention)CITY OF JANESVILLE Policy No. 84
CITY COUNCIL POLICY STATEMENT
Date Issued 5/11/2010
Reviewed 9/13/2021
Revised
General Subject: Identity Theft Protection Effective Date 5/11/2010
Special Subject: Red Flag Rules Cancellation Date ___________
Supersedes No.
Responsible
Dept/Div: Finance Office
PURPOSE
To establish an Identity Theft Prevention Program designed to detect, prevent, and
mitigate identity theft in connection with the opening of a covered account or an
existing covered account and to provide for continued administration of the
Program in compliance with Part 681 of Title 16 of the Code of Federal Regulations
implementing Sections 114 and 315 of the Fair and Accurate Credit Transactions
Act (FACTA) of 2003.
STATEMENT OF POLICY
In accordance with Federal Trade Commission regulations, the City establishes an
Identity Theft Prevention policy related to the opening and maintaining of covered
accounts which will identify, detect, and respond to patterns, practices, or specific
activities known as “red flags”.
1. Definitions
A. Identity Theft: Fraud committed or attempted using the
identifying information of another person.
B. Red Flag: A pattern, practice, or specific activity that indicates the
possible existence of identity theft.
C. Covered Accounts:
1. An account that the City offers or maintains, primarily for
personal, family, or household purposes that permits multiple
payments or transactions. Covered accounts related to City
operations include utility accounts and deferred special
assessment arrangements.
2. Any other account that the City offers or maintains for which
there is a reasonably foreseeable risk to customers or to the
safety and soundness of the City from identity theft.
2. Procedures
CITY OF JANESVILLE Policy No. 84
CITY COUNCIL POLICY STATEMENT
Date Issued 5/11/2010
Reviewed 9/13/2021
Revised
General Subject: Identity Theft Protection Effective Date 5/11/2010
Special Subject: Red Flag Rules Cancellation Date ___________
Supersedes No.
Responsible
Dept/Div: Finance Office
A “red flag” is a pattern, practice, or specific activity that indicates the possible
existence of identity theft. In order to detect, prevent, and mitigate these
activities, the City of Janesville establishes an identity theft prevention program
which includes reasonable policies and procedures to:
A. Identify relevant red flags for covered accounts it offers or maintains
and incorporate those red flags into the Program.
B. Detect red flags that have been incorporated into the Program.
C. Respond appropriately to any red flags that are detected to prevent
and mitigate identity theft.
D. Ensure the Program is updated periodically to reflect changes in risk
to customers and to the safety and soundness of the City from
identity theft.
3. Identification of Relevant Red Flags
In order to identify relevant red flags, the City considered the types of accounts it
offers and maintains, the methods it provides to open these accounts, the
methods it provides to access these accounts, and its previous experience with
identity theft. Based on this consideration, the City identified relevant red flags
from the following:
A. Notifications and warnings from consumer reporting agencies. This
would include: receiving a report or notice from a consumer reporting
agency of a credit freeze; or, receiving a report of fraud with a
consumer report.
CITY OF JANESVILLE Policy No. 84
CITY COUNCIL POLICY STATEMENT
Date Issued 5/11/2010
Reviewed 9/13/2021
Revised
General Subject: Identity Theft Protection Effective Date 5/11/2010
Special Subject: Red Flag Rules Cancellation Date ___________
Supersedes No.
Responsible
Dept/Div: Finance Office
B. The presentation of suspicious documents. This would include:
documents that appear to be forged or altered; documents on which a
person’s photograph or physical description is not consistent with the
person presenting the documentation; or, receiving documentation
with information that is not consistent with existing customer
information.
C. The presentation of suspicious personal identifying information. This
would include: a customer’s address or phone number being the
same as that of another customer; a customer failing to provide
complete personal identifying information on an application when
reminded to do so; or, a customer’s identifying information not being
consistent with the information that may be on file for the customer.
D. The unusual use of, or other suspicious activity related to, a covered
account. This would include: mail being sent to an account holder
that is repeatedly returned undeliverable; receiving notice that a
customer is not receiving his or her paper statements; or, a
customer’s account being used in a way that is not consistent with
the customer’s history (such as late or no payments when the
account has been timely in the past).
E. Notice from customers, victims of identity theft, law enforcement
authorities, or persons regarding possible identity theft in connection
with covered accounts.
4. Detection of Red Flags
In order to detect any of the red flags identified above, the City will:
A. Record change of address and transfer requests for existing accounts.
CITY OF JANESVILLE Policy No. 84
CITY COUNCIL POLICY STATEMENT
Date Issued 5/11/2010
Reviewed 9/13/2021
Revised
General Subject: Identity Theft Protection Effective Date 5/11/2010
Special Subject: Red Flag Rules Cancellation Date ___________
Supersedes No.
Responsible
Dept/Div: Finance Office
B. Verify the customer’s identity when opening a new account, such as
reviewing a driver’s license or other identification card, reviewing
property ownership records, or using other resources available.
C. Require sensitive data changes of existing accounts be completed in
writing and signed by the customer.
D. Require sensitive data (i.e. ACH banking information) be submitted in
writing for the opening of accounts and signed by the customer.
E. Monitor customer transaction history for unusual trends or
transactions.
5. Response
Any employee that may suspect fraud or detect a red flag will implement one or
more of the following responses as applicable in order to prevent and mitigate
identity theft. The response shall be commensurate with the degree of risk posed.
A. Continue to monitor the account for evidence of identity theft.
B. Contact the customer for additional information or documentation.
C. Reopen an account with a new account number.
D. Not open a new account.
E. Close an existing account.
F. Change any passwords, security codes or other security devices that
permit access to the account.
G. Notify law enforcement.
H. Determine no response is warranted under the particular
circumstances.
CITY OF JANESVILLE Policy No. 84
CITY COUNCIL POLICY STATEMENT
Date Issued 5/11/2010
Reviewed 9/13/2021
Revised
General Subject: Identity Theft Protection Effective Date 5/11/2010
Special Subject: Red Flag Rules Cancellation Date ___________
Supersedes No.
Responsible
Dept/Div: Finance Office
6. Updating the Program
The program shall be updated periodically to reflect changes in risks to customers
or to the safety and soundness of the City from identity theft. The following
factors will be taken into consideration in determining the necessity for updating
the program.
A. The experiences of the City with identity theft.
B. Changes in methods of identity theft.
C. Changes in methods to detect, prevent and mitigate identity theft.
D. Changes in the types of accounts that the City offers or maintains.
E. Changes in the business arrangements of the City.
7. Administration of Program
A. Each City Department or Division head shall be the Program
Administrator responsible for the development, implementation,
oversight and continued administration of the Program within their
respective Department or Division.
B. The program administrators shall be responsible for ensuring and
implementing the appropriate training for the Program. Staff training
shall be conducted for all employees, officials, and contractors for
whom it is reasonably foreseeable that they may come into contact
with accounts or personally identifiable information that may
constitute a risk to the City or its customers.
C. In the event the City engages a service provider to perform an activity
in connection with one or more accounts, the appropriate program
administrator shall ensure that all activities are conducted in
accordance with reasonable policies and procedures designed to
CITY OF JANESVILLE Policy No. 84
CITY COUNCIL POLICY STATEMENT
Date Issued 5/11/2010
Reviewed 9/13/2021
Revised
General Subject: Identity Theft Protection Effective Date 5/11/2010
Special Subject: Red Flag Rules Cancellation Date ___________
Supersedes No.
Responsible
Dept/Div: Finance Office
detect, prevent, and mitigate the risk of identity theft. A service
provider that maintains its own identity theft prevention program,
consistent with the guidance of the red flag rules and validated by
appropriate due diligence, will be considered to be meeting these
requirements.