For the effectiveness of identity theft prevention programs, the red flags rule envision a degree of confidentiality regarding the township’s specific practices relating to identity theft detection, prevention and mitigation. Therefore, under this program, knowledge of such specific practices are to be limited to the Identity Theft Committee and those employees who need to know them for purposes of preventing identity theft. Because this program is to be adopted by a public body and thus publicly available, it would be counterproductive to list these specific practices here. Therefore, only the program’s general red flag detection, implementation and prevention practices are listed in this document.
(Board and Administrative Policies Manual, § 4.83)