The Customer Service Department shall annually review and, as deemed necessary, update the identity theft prevention program along with any relevant red flags in order to reflect changes in risks to customers or to the safety and soundness of the Department and its covered accounts from identity theft. In so doing, the Department shall consider the following factors and exercise its discretion in amending the program:
(A) The Customer Service Department experiences with identity theft;
(B) Updates in methods of identity theft;
(C) Updates in customary methods used to detect, prevent, and mitigate identity theft;
(D) Updates in the types of accounts that all Utility Departments offer or maintain; and
(E) Updates in service provider arrangements.
(Ord. 2009-9, passed 5-13-2009)