(A) The Clerk-Treasurer’s office and office staff is responsible for oversight of the program and for program implementation. The Clerk-Treasurer is responsible for reviewing reports and/or suggestions made by the office staff and for recommending material changes to the program, as necessary in the opinion of the Clerk-Treasurer. Any recommended material changes to the program shall be submitted to the Town Council for consideration.
(B) The Clerk-Treasurer will report to the Town Council at least annually on compliance with red flag requirements. The Clerk-Treasurer will address material matters related to the program and evaluate issues such as:
(1) The effectiveness of the policies and procedures of the town in addressing the risk of identity theft in connection with the opening of covered accounts and with respect to existing covered accounts;
(2) Service provider agreements;
(3) Significant incidents involving identity theft and management’s response; and
(4) Recommendations for material changes to the program.
(C) The Clerk-Treasurer’s office is responsible for providing training to all employees responsible for, or involved in, opening a new covered account, restoring an existing covered account, or accepting a payment for a covered account with respect to the implementation and requirements of the Identity Theft Prevention Program. The Clerk-Treasurer shall exercise his or her discretion in determining the amount and substance of training necessary.
(Ord. G-09-03, passed 4-13-2009)