Responsibility for developing, implementing and updating this policy lies with the Village Administrator, subject to approval by the President and Board of Trustees. The Village Administrator will be responsible for the policy administration, for ensuring appropriate training of village staff on the policy, for reviewing any staff reports regarding the detection of red flags and the steps for preventing and mitigating identity theft, determining which steps of prevention and mitigation should be taken in particular circumstances and considering periodic changes to the policy.
(A) Staff training and reports. Village personnel responsible for implementing the policy shall be trained either by or under the direction of the Village Administrator in the detection of red flags, and the responsive steps to be taken when a red flag is detected.
(B) Service provider arrangements. In the event the village engages a service provider to perform an activity in connection with one or more accounts, the village will take the following steps to ensure the service provider performs its activity in accordance with the policy set forth herein:
(1) Require, by contract, that service providers have such policies and procedures in place; and
(2) Require, by contract, that service providers review the village’s policy and report any red flags to the Village Administrator.
(Res. 2008-1031, passed 11-5-08)