(a) Implementation.
(1) Implementation of the program is delegated to the Village Clerk.
(b) Staff Training.
(1) Training should be conducted for employees and contractors who work with covered accounts.
(2) The Village Clerk is responsible for identity theft training for all such employees and contractors.
(c) Oversight of Service Provider Arrangements.
(1) The municipality should ensure that the activities of all service providers are conducted in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft.
(2) A service provider that maintains its own identity theft prevention program, consistent with the guidance of the red flag rules, may be considered to be meeting these requirements.
(3) Any specific requirements should be specifically addressed in the appropriate contract arrangements.
(Ord. 03-09. Passed 4-20-09.)