(A) The town is a creditor pursuant to 16 C.F.R. § 681.2 due to its provision or maintenance of covered accounts for which payment is made in arrears.
(B) Covered accounts offered to customers for the provision of services include water utility and stormwater utility, customers requiring any service or record from the Town Marshal’s office, customers applying for the issuance of any permit required by the town and any and all other creditors who may pay their obligation to the town by means of electronic transmission.
(C) The town’s previous experience with identity theft related to covered accounts is as follows: no known incidents.
(D) The processes of opening a new covered account, restoring an existing covered account, making payments on such accounts, and providing account information, access in person or via phone or website have been identified as potential processes in which identity theft could occur.
(E) The town limits access to personal identifying information to those employees responsible for or otherwise involved in opening or restoring covered accounts or accepting payment for use of covered accounts. Information provided to such employees is entered directly into the town’s computer system and is not otherwise recorded.
(F) The town determines that there is a low risk of identity theft occurring in the following ways (if any):
(1) Use by an applicant of another person’s personal identifying information to establish a new covered account;
(2) Use of a previous customer’s personal identifying information by another person in an effort to have service restored in the previous customer’s name;
(3) Use of another person’s credit card, bank account, or other method of payment by a customer to pay such customer’s covered account or accounts; and
(4) Use by a customer desiring to restore such customer’s covered account of another person’s credit card, bank account, or other method of payment.
(Ord. 030915, passed 3-23-2015)