(A) Town of Albion Water and Wastewater Utility Identity Theft Prevention Program. This plan is intended to identify red flags that will alert employees when new or existing accounts are opened using false information, protect against the establishment of false accounts, provide methods to ensure existing accounts were not opened using false information, and recite measures to respond to such events.
(B) Risk assessment. The Town of Albion Water and Wastewater Utility has conducted an internal risk assessment to evaluate how at risk the current procedures are at allowing customers to create a fraudulent account and evaluate if current (existing) accounts are being manipulated. This risk assessment evaluated how new accounts were opened and the methods used to access the account information. Using this information, the utility was able to identify red flags that were appropriate to prevent identity theft:
(1) New accounts opened in person;
(2) New accounts opened via telephone;
(3) New accounts opened via fax;
(4) New accounts opened via mail;
(5) Account information accessed in person; and
(6) Account information accessed via telephone (person).
(C) Detection (red flags). The town adopts the following red flags to detect potential fraud. These are not intended to be all-inclusive and other suspicious activity may be investigated as necessary:
(1) Identification documents appear to be altered;
(2) Photo and physical description do not match appearance of applicant;
(3) Other information is inconsistent with information provided by applicant;
(4) Other information provided by applicant is inconsistent with information on file;
(5) Application appears altered or destroyed and reassembled;
(6) Personal information provided by applicant does not match other sources of information (e.g., credit reports, social security number not issued or listed as deceased);
(7) Lack of correlation between the social security number range and place of birth;
(8) Information provided is associated with known fraudulent activity (e.g., address or telephone number provided is same as that of a fraudulent application);
(9) Information commonly associated with fraudulent activity is provided by applicant (e.g., address that is a mail drop or prison, non-working phone number or associated with answering service/pager);
(10) Social security number, address, or telephone number is the same as that of other customers at the utility;
(11) Customer fails to provide all information requested;
(12) Personal information provided is inconsistent with information on file for a customer;
(13) Applicant cannot provide information requested beyond what could commonly be found in a purse or wallet; and/or
(14) Identity theft is reported or discovered.
(D) Response. Any employee that may suspect fraud or detect a red flag will implement the following response as applicable. All detections or suspicious red flags shall be reported to the Clerk-Treasurer and/or Town Manager.
(1) Ask applicant for additional documentation;
(2) Notify the Albion Police Department at 260-636-7157 of any attempted or actual identity theft;
(3) Do not open the account;
(4) Close the account; and/or
(5) Do not attempt to collect against the account, but notify authorities.
(E) Personal information security procedures. The Town of Albion Water and Wastewater Utility adopts the following security procedures.
(1) Employees will conceal sensitive data from view when they are away from their workstations.
(2) Paper documents, files, and electronic media containing secure information will be stored in locked file cabinets and/or in the locked records room.
(3) Access to storage facilities is limited to employees/auditors with a legitimate business need.
(4) Visitors who must enter areas where sensitive files are kept must be escorted by an employee of the utility.
(5) When sensitive data is received or transmitted, secure connections will be used.
(6) Computer passwords are to be shared only with those employees assigned to utilize specific workstations.
(F) Identity Theft Prevention Program review and approval. This plan has been reviewed and adopted by the Albion Town Council. Appropriate employees have been trained on the contents and procedures of this Identity Theft Prevention Program. The effectiveness of the policies and procedures will be reviewed annually and updated as needed.
(Ord. 2009-04, passed 4-28-09; Am. Ord. 2010-05, passed 4-27-10)