(A) The Program shall provide for appropriate responses to detected red flags to prevent and mitigate identity theft.
(1) The response shall be commensurate with the degree of risk posed.
(2) In all cases, red flags should be reported to the Finance Director.
(B) Appropriate responses may include:
(1) Monitoring a covered account for evidence of identity theft.
(2) Contacting the owner of the account in question via written letter or phone number on record.
(3) Changing any passwords, security codes or other security devices that permit access to a covered account.
(4) Terminating transaction.
(5) Reopening a covered account with a new account number.
(6) Not opening a new covered account.
(7) Closing an existing covered account.
(8) Notifying law enforcement.
(9) Determining no response is warranted under the particular circumstances.
(C) The city shall address the detection of red flags in connection with the opening of covered accounts and existing covered accounts by:
(1) Obtaining identifying information about customers through photo ID verification upon application for service.
(2) Requiring an alternative identification method if photo ID appears to be altered or forged.
(3) Rejecting any application for service that appears to have been altered or forged.
(4) Requiring lease confirmations on covered accounts with customer name and address information.
(5) Requiring confirmation of ownership on covered accounts with customer name and address information.
(6) Requiring confirmation of Social Security number on covered accounts.
(7) The city does not use any outside agencies for credit checks, therefore, any verification process pertaining to outside agencies does not apply.
(Res. 09-005, passed 7-14-09)