(A) The village is committed to detecting situations in which identity theft might have or may have occurred.
(B) A RED FLAG is a pattern, practice or specific activity that indicates the possible existence of identity theft. In order to identify relevant red flags, the village considered risk factors such as the types of accounts that it offers and maintains, the methods it provides to open its accounts, the methods it provides to access its accounts and its previous experiences with identity theft.
(C) Identity theft will be combated by detecting red flags in connection with the opening of covered accounts and existing covered accounts, such as by:
(1) Obtaining identifying information about, and verifying the identity of, a person opening a covered account;
(2) Authenticating customers’ transactions, including photo ID if necessary, plus possible additional verification methods such as a user ID and password;
(3) Monitoring transactions with emphasis on a change of address closely followed by a new service request or a material change in a customer’s credit use; and
(4) Verifying the validity of change of address requests, in the case of existing covered accounts in order to monitor the diversion of statements as a prelude to possible account manipulation.
(2009 Code, § 22-1-3)