In order to prevent and mitigate identity theft, the village will provide appropriate responses to the following red flags.
(A) Alerts, notifications or warnings from a consumer reporting agency.
(1) A fraud or active duty alert is included with a credit report.
(2) A credit reporting agency provides a notice of credit freeze in response to a request for a credit report.
(3) A credit reporting agency provides a notice of address discrepancy.
(4) Receiving a report of fraud with a credit report.
(5) Receiving indication from a credit report of activity that is inconsistent with a customer’s usual pattern or activity.
(B) Suspicious documents.
(1) Documents provided for identification appear to have been altered, forged or unauthentic.
(2) The photograph or physical description on the identification is not consistent with the appearance of the applicant or person presenting the identification.
(3) Receiving other documentation with information that is not consistent with existing customer information (such as if a person’s signature on a check appears forged).
(4) Receiving an application for service that appears to have been altered or forged.
(C) Suspicious personal identifying information.
(1) The person opening the covered account or the customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
(2) Personal identifying information provided is not consistent with personal identifying information that is on file with the village.
(3) A person’s identifying information is the same as shown on other applications found to be fraudulent.
(4) A person’s identifying information is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address).
(5) A person’s Social Security number is the same as another customer’s Social Security number.
(6) A person’s address or phone number is the same as that of another person.
(7) A person’s identifying information is not consistent with other information the customer provides.
(D) Unusual use of, or suspicious activity related to, the covered account.
(1) A change of address for a covered account followed by the village receiving a request for the addition of authorized users on the account or adding other parties.
(2) A covered account that has been inactive and then becomes active.
(3) Payments stop on an otherwise consistently up-to-date account.
(4) Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s covered account.
(5) The village is notified of unauthorized charges or transactions in connection with a customer’s covered account.
(6) A new account is used in a manner consistent with fraud (such as the customer failing to make the first payment, or making the initial payment and no other payments).
(5) An account being used in a way that is not consistent with prior use (such as late or no payments when the account has been timely in the past).
(7) The village receives notice that a customer is not receiving his or her paper statements.
(E) Notice from customers, victims of identity theft, law enforcement authorities or other persons regarding possible identity theft in connection with covered accounts held by the village.
(1) The village is notified by a customer, a victim of identity theft, a law enforcement authority or any other person that it has opened a fraudulent account for a person engaged in identity theft.
(2) (a) Should any of the above instances of suspicious activity that could be identity theft occur, the village will take immediate actions to either prevent or mitigate the situation.
(b) In order to detect any of the red flags identified above with the opening of a new account, village personnel will take the following steps to obtain and verify the identity of the person opening the account. Steps can include:
1. Requiring certain identifying information such as name, date of birth, residential or business address, principal place of business for an entity, Social Security number, driver’s license or other identification;
2. Verifying the customer’s identity, such as by copying and reviewing a driver’s license or other identification card;
3. Reviewing documentation showing the existence of a business entity; and
4. Independently contacting the customer.
(c) In order to detect any of the red flags identified above for an existing account, village personnel will take the following steps to monitor transactions with an account. Steps can include:
1. Verifying the identification of customers if they request information (in person, via telephone, via facsimile, via e-mail);
2. Verifying the validity of requests to change billing addresses; and
3. Verifying changes in banking information given for billing and payment purposes. Responses to these red flags are commensurate with the degree of risk posed based on the village’s risk assessment. Appropriate responses may include the following:
a. Complete verification of identification for fraud, active duty, credit freeze or address discrepancy alert for any of these types of alerts found on a consumer credit report when applying for services;
b. Monitoring a covered account for evidence of identity theft or suspicious activity by placing on the village’s watch list;
c. Contacting the customer;
d. Changing any passwords, security codes or other security devices that permit access to a covered account;
e. Reopening a covered account with a new account number;
f. Not opening a new covered account;
g. Closing an existing covered account;
h. Not attempting to collect on a covered account or not sending a covered account to a debt collector;
i. Notifying law enforcement; or
j. Determining that no response is warranted under the particular circumstances.
(2009 Code, § 22-1-4)