147.03  THE PROGRAM.
   (a)   The Village of Forest establishes this Identity Theft Prevention Program to detect, prevent, and mitigate identity theft.  This Program includes reasonable policies and procedures to:
      (1)   Identify relevant red flags for covered accounts it offers or maintains and incorporate those red flags into the Program;
      (2)   Detect red flags that have been incorporated into the Program;
      (3)   Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
      (4)   Ensure the Program is updated periodically to reflect changes in risks to customers and to the safety and soundness of the creditor from identity theft.
   (b)   This program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.
   (c)   Municipal personnel are encouraged to use common sense judgment in securing confidential information to the proper extent.  Furthermore, this policy should be read in conjunction with the Ohio Public Records Act and the municipality’s open records policy.  If an employee is uncertain of the sensitivity of a particular piece of information, the employee should contact his/her supervisor.  In the event that the municipality cannot resolve a conflict between this policy and the Ohio Public Records Act, the municipality will consult legal counsel.
(Ord. 1775.  Passed 9-10-09.)