(A) (1) The town’s Clerk-Treasurer is responsible for oversight of the program and for program implementation. The town’s Administrator is responsible for reviewing reports prepared by staff regarding compliance with red flag requirements and with recommending material changes to the program, as necessary in the opinion of the town’s Administrator, to address changing identity theft risks and to identify new or discontinued types of covered accounts.
(2) Any recommended material changes to the program shall be submitted to the town’s Board of Trustees for consideration by the Board of Trustees.
(B) The town’s Clerk-Treasurer will report to the town’s Administrator, at least annually, on compliance with the red flag requirements. The report will address material matters related to the program and evaluate issues such as:
(1) The effectiveness of the policies and procedures of the town in addressing the risk of identity theft in connection with the opening of covered accounts and with respect to existing covered accounts;
(2) Service provider arrangements;
(3) Significant incidents involving identity theft and management’s response; and
(4) Recommendations for material changes to the program.
(C) (1) The town’s Clerk-Treasurer is responsible for providing training to all employees responsible for or involved in opening a new covered account, restoring an existing covered account or accepting payment for a covered account with respect to the implementation and requirements of the identity theft prevention program.
(2) The town’s Clerk-Treasurer shall exercise his or her discretion in determining the amount and substance of training necessary.
(Prior Code, § 3-1-9) (Ord. 2009-4, passed 5-11-2009)