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
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:
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
B. Suspicious Documents
C. Suspicious Personal Identifying Information
D. Suspicious Covered Account Activity or Unusual Use of Account
E. Alerts from Others
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:
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:
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:
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
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:
VI. PROGRAM ADMINISTRATION
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.
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