(A) The town shall annually review and, as deemed necessary, update the Identity Theft Prevention Program along with any relevant red flags in order to reflect changes in risks to customers or to the safety and soundness of the town and its covered accounts from identity theft.
(B) In so doing, the town shall consider the following factors and exercise its discretion in amending the program:
(1) The town’s experiences with identity theft;
(2) Updates in methods of identity theft;
(3) Updates in customary methods used to detect, prevent and mitigate identity theft;
(4) Updates in the types of accounts that the town offers or maintains; and
(5) Updates in service provider arrangements.
(Ord. 2009-5, passed 4-27-09)