(A) Oversight. Responsibility for developing, implementing, and updating this program lies with an Identity Theft Committee consisting of three members, including the Program Administrator. The Committee shall be headed by a Program Administrator, which may be the Village Clerk, or his or her appointee. The Village Clerk or the Program Administrator shall appoint two individuals to comprise the remainder of the Committee. The Program Administrator will be responsible for oversight and administration of the program, for ensuring appropriate training of village staff on the program, for reviewing any staff reports concerning the detection of red flags and the steps for preventing and mitigating identity theft, determining which steps of prevention and mitigation should be taken in particular circumstances, and considering periodic changes to the program.
(B) Staff training and reports. Village personnel responsible for implementing the program shall be trained either by or under the direction of the Program Administrator in the detection of red flags, and the responsive steps to be taken when a red flag is detected.
(C) Service provider arrangements. In the event the village engages a service provider to perform an activity in connection with one or more accounts, the village will take the following steps to ensure the service provider performs its activity in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft:
(1) Require, by contract, that service providers have such policies and procedures in place; and
(2) Require, by contract, that service providers review the village’s program and report any red flags to the Program Administrator.
(D) Specific program elements and confidentiality. In order to ensure confidentiality as contemplated by the Red Flags Rules, knowledge of the village’s specific practices relating to identity theft detection, prevention, and mitigation shall be limited to the Identity Theft Committee, the Village Clerk, and those employees who are involved in the day-to-day implementation of this program.
(Res. 09-R-1, passed 4-21-2009)