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Identity Theft, determining which steps of prevention and mitigation should be taken <br />in particular circumstances and considering periodic changes to the Program. <br />B. Staff Traininq and Reports <br />Utility staff responsible for implementing the Program shall be trained either by <br />or under the direction of the Program Administrator in the detection of Red Flags, and <br />the responsive steps to be taken when a Red Flag is detected. <br />Staff will provide reports to the Program Administrator on incidents of Identity <br />Theft, the Utility's compliance with the Program and the effectiveness of the Program. <br />C. Service Provider Arranqements <br />In the event the Utility engages a service provider to perform an activity in <br />connection with one or more accounts, the Utility will take the following steps to <br />ensure the service provider performs its activity in accordance with reasonable <br />policies and procedures designed to detect, prevent, and mitigate the risk of Identity <br />Theft. <br />1. Require, by contract, that service providers have such policies and procedures <br />in place; and <br />2. Require, by contract, that service providers review the Utility's Program and <br />report any Red Flags to the Program Administrator. <br />~ i;(l(a(~~:~ <br />