The City Recorder will review and update the program at least once a year to reflect changes in risks to customers and the soundness of the utility from identity theft. In doing so, the City Recorder will consider the utility’s experiences with identity theft situations, changes in identity theft methods, changes in identity theft detection and prevention methods, and changes in the utility’s business arrangements with other entities. After considering these factors, the City Recorder will determine whether changes to the program, including the listing of red flags, are warranted. If warranted, the City Recorder will update the program or present the City Council with his or her recommended changes and the City Council will make a determination of whether to accept, modify or reject those changes to the program.
(Res. 2009-03, passed 5-7-2009)