§ 40.23 ESTABLISHMENT OF THE PROGRAM.
   (A)   The city establishes an Identity Theft Prevention Program to detect, prevent and mitigate identity theft.
   (B)   The Program shall include reasonable policies and procedures to:
      (1)   Identify relevant red flags for covered accounts it offers or maintains, 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.
      (4)   Ensure the Program is updated periodically to reflect changes in risks to customers, and to the safety and soundness of the creditor from identity theft.
   (C)   The Program shall, as appropriate, incorporate existing policies and procedures that control reasonable foreseeable risks.
(Res. 09-005, passed 7-14-09)