The Town Manager will be responsible for overseeing the implementation, management, and updating of this new policy and shall have the following responsibilities:
   (A)   Assign specific responsibility for the program’s implementation, including appropriate training for staff;
   (B)   At least annually, the assigned person/staff must report to the Board of Commissioners and provide an update on the policy’s effectiveness, any service provider arrangements, and significant incidents involving identity theft and the town’s response, and recommendations for ways to improve the program;
   (C)   Review reports prepared by staff to ensure that the town remains compliant with its legal responsibility to maintain an identity theft prevention program; and
   (D)   Approve material changes to this program as necessary to address changing identity theft risks.
(2013 Code, § 18-67.6)