(A) The town has conducted an internal risk assessment to evaluate how at risk the current procedures are at allowing customers to create a fraudulent account and evaluate if current (existing) accounts are being manipulated.
(B) This risk assessment evaluated how new accounts were opened and the methods used to access the account information.
(C) Using this information, the Utility was able to identify red flags that were appropriate to prevent identity theft:
(1) New accounts opened in person;
(2) Account information accessed in person; and
(3) Account information accessed via telephone (person).
(Res. 2009-02, passed 4-21-2009)