1. Dover Township (the “Township”) has conducted an internal risk assessment with necessary staff to evaluate how at risk the current procedures are at allowing customers to create fraudulent accounts and evaluate if current and existing accounts are being manipulated or can be manipulated. The Township reviewed each red flag and determined its applicability, if any, to the Township.
2. The Township reviewed sewer and water accounts (“utility accounts”). It was determined that the accounts run with the property and not the property owner. The Township provides the account number. The only personal information provided is the property owner’s name and property address. The Township does not maintain any personal information or background information such as Social Security numbers, date of births or driver’s license information. No application is provided. The real estate transfer is the trigger for the account. The account is always in the property owner’s name as indicated on the deed. Since the account runs with the property, it would be impossible for some one to open a fraudulent account.
3. The Township does not accept payment by credit card and does not speak to any credit agencies on behalf of the Township. Information about an account is not provided over the telephone. Staff with access to these accounts is minimal.
4. The Township invoices customers with use of a card. The card does not provide any personal or protected information. It provides:
A. Name and address.
B. Account number which is unique to the property address.
C. Usage and amount due.
5. It was determined that this information is not personal identifying information and could not result in any identity theft.
6. The Township determined that the customer’s utility accounts are at a low to very low risk for identity theft.
(Ord. 2009-02, 3/23/2009, §IV)