A. Oversight: Responsibility for developing, implementing and updating this program lies with an Identity Theft Committee for the City. The committee will be comprised of the Finance Director, City Treasurer and Information Systems Director (or their designees). The committee will be responsible for program administration, for ensuring appropriate training of City staff on the program, 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 program.
B. Staff Training And Reports: City staff responsible for implementing the program shall be trained either by or under the direction of the Identity Theft Committee in the detection of red flags, and the responsive steps to be taken when a red flag is detected. City staff are required to provide reports to the committee on incidents of identity theft, the City's compliance with the program and the effectiveness of the program.
C. Specific Program Elements And Confidentiality: For the effectiveness of Identity Theft Prevention Programs, the Red Flag Rule envisions a degree of confidentiality regarding the City's specific practices relating to identity theft detection, prevention and mitigation. Therefore, under this program, knowledge of such specific practices are to be limited to the Identity Theft Committee and those employees who need to know them for purposes of preventing identity theft. Because this program is to be adopted by the Mayor and thus publicly available, it would be counterproductive to list these specific practices here. Therefore, only the program's general red flag detection, implementation and prevention practices are listed in this document. (2019 Compilation)