I.  PROGRAM ADOPTION

Howard Community College (college) developed this Identity Theft Prevention Program (program) pursuant to the Federal Trade Commission's (FTC) Red Flags Rule, which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003.  This program was developed with approval of the Howard Community College Board of Trustees.   

II.  DEFINITIONS AND PROGRAM

A.        Red Flags Rule Definitions Used in this Program

1. Identity theft is a fraud committed or attempted using the identifying information of another person without authority. 
2. A Red Flag is a pattern, practice, or specific activity that indicates the possible existence of identity theft. 
3. A covered account includes all student accounts or loans that are administered by the college. 
4. Program administrator is the individual designated with primary responsibility for oversight of the program.  The program administrator will be the vice president of information technology. 
5. A Committee under the direction of the program administrator will be established to carry out the program.  In addition to representation from information technology, other members of the committee will be from the areas of student services and administration and finance.    
6. Identifying information is any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including: name, maiden name, address, telephone number, social security number, date of birth, government issued driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, credit card information, or computer internet protocol (IP) address. 
7. Implementation will occur on or before May 1, 2009. 

B.        Fulfilling Requirements of the Red Flags Rule

Under the Red Flags Rule, the college is required to establish an Identity Theft Prevention Program tailored to its size, complexity and the nature of its operation.  The program must contain reasonable policies and procedures to:

1. Identify relevant red flags for new and existing covered accounts and incorporate those red flags into the program and incorporate existing policies and procedures into the program;
2. Detect red flags that have been incorporated into the program;
3. Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
4. Ensure the program is updated periodically to reflect changes in risks to students or to the safety of the student from identity theft. 

III.  IDENTIFICATION OF RED FLAGS

In order to identify relevant red flags, the college considers the types of accounts that it offers and maintains, methods it provides to open its accounts, methods it provides to access its accounts, and its previous experiences with identity theft.  The college identifies the following red flags in each of the listed categories:

A.  Notifications and Warnings from Consumer Reporting Agencies or other Organizations

Red Flags

1. Report of fraud; 
2. Notice or report from a credit agency of a fraud or active duty alert for an applicant;
3. Notice of address discrepancy;  and
4. Indication from a credit report of activity that is inconsistent with an applicant’s usual pattern or activity. 

B.        Suspicious Documents

Red Flags

1. Identification document or card that appears to be forged, altered, or inauthentic;
2. Identification document or card on which a person’s photograph or physical description is not consistent with the appearance of the person presenting the document;
3. Other document with information that is not consistent with existing student information; and
4. Application for service that appears to have been altered or forged. 

C.        Suspicious Personal Identifying Information

Red Flags

1. Identifying information presented that is inconsistent with other information the student provides (example: inconsistent birth dates) or with information that is on file for the student;
2. Identifying information presented that is inconsistent with other sources of information;
3. Identifying information presented that is the same as information shown on other applications that were found to be fraudulent;
4. Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address); and
5. Social security number presented that is the same as one given by another student.

D.        Suspicious Covered Account Activity or Unusual Use of Account

Red Flags

1. Change of address for an account followed by a request to change the student’s name;
2. Account used in a way that is not consistent with prior use;
3. Mail sent to the student is repeatedly returned as undeliverable;
4. Notice to the college that a student is not receiving mail sent by the college;
5. Notice to the college that an account has unauthorized activity;
6. Breach in the college's computer system security; and
7. Unauthorized access to or use of student account information. 

E.         Alerts from Others

Red Flag

1. Notice to the college from a student, identity theft victim, law enforcement, or other person that the college has opened or is maintaining a fraudulent account for a person engaged in identity theft. 

IV.  DETECTING RED FLAGS

A.        Student Enrollment

In order to detect any of the red flags associated with the enrollment of a student, college personnel will take the following steps to obtain and verify the identity of the person opening the account:

1. Require identifying information as stated in the college catalog.
2. Verify the student’s identity, as stated in the college catalog, at time of issuance of HCC student identification card.   

B.        Existing Accounts

In order to detect any of the red flags for an existing covered account, college personnel will take the following steps to monitor transactions on an account:

Detect

1. Verify the identification of students if they request information (in person, via telephone, via facsimile, via email);
2. Verify the validity of requests to change billing addresses by mail or email and provide the student a reasonable means of promptly reporting incorrect billing address changes; and
3. Verify changes in payment information given for billing and payment purposes. 

C.        Employee Background Report Requests

In order to detect any of the red flags for an employment or volunteer position for which a criminal background report is sought, college personnel will take the following steps to assist in identifying address discrepancies:

1. Require written verification from any applicant that the address provided by the applicant is accurate at the time before the request for the background report is made to the consumer reporting agency.

V.  PREVENTING AND MITIGATING IDENTITY THEFT

In the event college personnel detect any identified red flags, such personnel shall take one or more of the following steps, depending on the degree of risk posed by the red flag:

Prevent and Mitigate

1. Continue to monitor a covered account for evidence of identity theft;
2. Contact the student;
3. Change any passwords or other security devices that permit access to covered accounts;
4. Not open a new covered account;
5. Provide the student with a new student identification number;
6. Notify the program administrator for determination of the appropriate step(s) to take;
7. Notify law enforcement;
8. File or assist in filing a Suspicious Activities Report; or
9. Determine that no response is warranted under the particular circumstances. 

Protect Student Identifying Information

In order to further prevent the likelihood of identity theft occurring with respect to covered accounts, the college will take the following steps with respect to its internal operating procedures to protect student identifying information:

1. Ensure that its website is secure or provide clear notice that the website is not secure;
2. Ensure complete and secure destruction of paper documents and computer files containing student account information when a decision has been made to no longer maintain such information;
3. Ensure that office computers with access to covered account information are password protected;
4. Avoid use of social security numbers;
5. Ensure computer virus protection is up-to-date; and
6. Require and keep only the kinds of student information that are necessary for college purposes. 

VI.  PROGRAM ADMINISTRATION

A.        Oversight

Responsibility for developing, implementing, and updating this program lies with an identity theft committee (committee) for the college.  The committee is headed by a program administrator who will be the vice president of the information technology.  Two or more other individuals from the areas of student services and administration and finance in addition to the program administrator comprise the committee membership.  The program administrator or his/her designee will be responsible for ensuring appropriate training of college 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.  Periodic audits of various areas will be conducted.

B.        Staff Training and Reports

College staff responsible for implementing the program shall be trained either by or under the direction of the program administrator or his/her designee in the detection of red flags and the responsive steps to be taken when a Red Flag is detected.  College staff shall be trained, as necessary, to effectively implement the program.  College employees are expected to notify the program administrator once they become aware of an incident of identity theft or of the college’s failure to comply with this program.  At least annually, or as otherwise requested by the program administrator, college staff responsible for development, implementation, and administration of the program shall report to the program administrator on compliance with this program.  The report should address such issues as effectiveness of the policies and procedures in addressing the risk of identity theft in connection with the opening and maintenance of covered accounts, service provider arrangements, and significant incidents involving identity theft and management’s response and recommendations for changes to the program.

C.        Service Provider Arrangements

In the event the college engages a service provider to perform an activity in connection with one or more covered accounts, the college will take the following steps to ensure the service provider performs its activity in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft. 

1. Require, by contract, that service providers have such policies and procedures in place; and
2. Require, by contract, that service providers review the college's program and report any red flags to the program administrator or the college employee with primary oversight of the service provider relationship. 

D.        Non-disclosure of Specific Practices

For the effectiveness of this identity theft prevention program, knowledge about specific red flag identification, detection, mitigation and prevention practices may need to be limited to the committee who developed this program and to those employees with a need to know them.  Any documents that may have been produced or are produced in order to develop or implement this program that list or describe such specific practices and the information those documents contain are considered confidential and should not be shared with other employees or the public.  The program administrator shall inform the committee and those employees with a need to know the information of those documents or specific practices that should be maintained in a confidential manner. 

E.         Program Updates

The committee will periodically review audit, and update this program to reflect changes in risks to students and the security of the college from identity theft.  In doing so, the committee will consider the college's experiences with identity theft situations, changes in identity theft methods, changes in identity theft detection and prevention methods, and changes in the college's business arrangements with other entities.  After considering these factors, the program administrator will determine whether changes to the program, including the listing of red flags, are warranted.  If warranted, the committee will update the program.

Policy Manual Review/Revision:  05/01/09