§ 38.04 ACCOUNT OPENING PROCEDURES.
   Whiteland Utility employees will adhere to the following procedures in initiating new accounts to protect against accounts being opened under fake names or stolen identities:
   (A)   Employees will request customers applying for new accounts by telephone to provide the following information:
      (1)   Name;
      (2)   Address;
      (3)   Phone number;
      (4)   Employer;
      (5)   Date of birth; and
      (6)   Social Security number.
   (B)   The prospective customer's Social Security number will be entered into a reputable Social Security search database to ensure the number is valid and compare the reported date of birth for the provided Social Security number with the birth date given by the customer.
      (1)   If the Social Security number provided is valid and matches the customer's date of birth, the account may be opened (unless the employee has other reasonable grounds for suspicion).
      (2)   If the Social Security number comes back invalid, raises suspicion about its validity or does not match the customer's date of birth, the employee must request the customer appear at a Whiteland Utility office in person and present a valid form of photo ID to establish their identity.
   (C)   For a customer that appears to open an account in person, a valid photo ID and all information provided in division (A) shall be provided.
   (D)   In reviewing the information provided by the prospective customers, employees should look for the following red flags:
      (1)   Identification documents provided appear to be altered;
      (2)   Any discrepancy between the information provided by the potential customer and the results of the Social Security check;
      (3)   Photo and physical description on photo ID do not match appearance of potential customer;
      (4)   Information provided by the potential customer does not match other sources of information;
      (5)   Social Security number, address or telephone number is the same as that of another customer of Whiteland Utilities;
      (6)   Potential customer cannot provide information requested beyond what could commonly be found in a purse or wallet; or
      (7)   Identity theft is reported or discovered.
   (E)   Employees shall take steps to ensure an account is not opened under a false name including refusing to open an account if satisfactory identifying information is not provided.
(Res. 09-4, passed 10-13-09)