(A) The Department endeavors to identity relevant red flags as they relate to possible risk of identity theft in connection with the Department’s covered accounts. Inconsistent documents, information or activity encountered when dealing with customer accounts and financial transactions may signal identity theft. In order to identify relevant red flags, the Department shall initially and annually review and consider the types of covered accounts that it offers and maintains, the methods it provides to open covered accounts, the methods it provides to access its covered accounts, and its previous experiences with identity theft.
(B) The town identifies the following relevant red flags at present, which it will consider in detecting identity theft.
(1) Suspicious documents.
(a) Documents provided for identification that appear to be forged or altered;
(b) Documents provided for identification on which a person’s photograph or physical description is inconsistent with the person presenting the document;
(c) Other document with information that is not consistent with existing customer information (for example, a person’s signature on a check appears forged);
(d) Application for services or account setup that appears to have been altered or forged; and
(e) Social Security numbers that are always invalid:
1. The first three digits are in the 772—800 or the 900 range;
2. The first three digits are 666; or
3. The first three digits are 000, or the fourth and fifth digits are 00, or the last four digits are 0000.
(2) Suspicious personal identifying information.
(a) Identifying information presented that is inconsistent with other information the customer provides, or information that is on file for that customer (such as inconsistent birth dates);
(b) Identifying information presented that is inconsistent with other sources of information (for instance, an address not matching an address on a driver’s license, or signatures that do not appear to match other documents);
(c) Identifying information presented that is the same as information that is included on applications that are known to be fraudulent (such as a name or Social Security number that has been identified as being fraudulent on other prior applications received for various applicants);
(d) Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address);
(e) Identifying information presented, such as a Social Security number, phone number or address that is the same as one given by another customer; and
(f) Failing to provide complete personal identifying information on an application when reminded to do so.
(3) Unusual use or suspicious activity of covered account.
(a) Change of billing address for an account followed by a request to change the account holder’s name or add other authorized user(s) on the account;
(b) Payments stop on an otherwise consistently up-to-date account;
(c) Account used in a way that is not consistent with prior use (such as very high activity);
(d) Change of payment method where payment is charged to an individual not listed on the account;
(e) Mail sent to the account holder is repeatedly returned as undeliverable;
(f) Notice to the Department that a customer is not receiving mail sent by the Department;
(g) Notice to the Department that an account has unauthorized activity;
(h) Breach in the Department computer system security; and
(i) Unauthorized access to or use of customer account information.
(4) Alerts from others or past history in incidents of identity theft.
(a) Notice to the Department from a customer, a victim of identity theft, a law enforcement authority or other person that it has opened or is maintaining a fraudulent account for a person engaged in identity theft;
(b) Checks returned for insufficient funds or credit card payments or EFTs that are declined, especially when a pattern is noticed or following a change in method of payment; and
(c) Past experiences the Department has had regarding incidents of identity theft, when similar patterns or events are noticed by the town.
(Res. 2011-04, passed 3-14-2011)