3-3-1: PURPOSE:
   A.   The City has developed this Identity Theft Prevention Program ("program") pursuant to the Federal Trade Commission's Red Flags Rule ("rule"), which implements section 114 of the Fair and Accurate Credit Transactions Act of 2003 by implementing reasonable procedures to:
      1.   Identify relevant red flags for new and existing covered accounts and incorporate those red flags into the program;
      2.   Detect red flags that have been incorporated into the program;
      3.   Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
      4.   Ensure the program is updated periodically to reflect changes in risks to customers or to the safety and soundness of the creditor from identity theft.
   B.   A degree of confidentiality regarding the City's specific practices relating to identity theft detection, prevention and mitigation is required to ensure the effectiveness of the Identity Theft Prevention Program. Therefore, only the City's general practices related to implementation of red flag detection, prevention and mitigation are listed in this chapter. Any documents that may have been produced or are produced in order to develop or implement the Identity Theft Prevention Program established by this chapter that list or describe such specific practices and the information those documents contain are considered "security information" as defined in Minnesota Statutes section 13.37 and are unavailable to the public because disclosure of them would be likely to substantially jeopardize the security of information against improper use, that use being to circumvent the City's identity theft prevention efforts in order to facilitate the commission of identity theft. (Prior Code § 2-6-1)