Laserfiche WebLink
2. Identifying Red Flags <br />In order to identify relevant Red Flags, the City considers the types of <br />accounts that it offers and maintains, the methods it provides to open its accounts, <br />the methods it provides to access its accounts, and its previous experiences with <br />Identity Theft. The City identifies the red flags in each of the following categories: (1) <br />Suspicious Documents; (2) Suspicious Personal Identifying Information; (3) <br />Suspicious Account Activity or Unusual Use of Account; and (4) Alerts From Others. <br />3. Other Steps That a City Must Take <br />Cities must also take the following steps: (1) Detect Red Flags-for new <br />accounts and existing accounts; (2) Prevent and Mitigate Identity Theft-includes <br />protecting customers' identifying information; (3) Program Updates; and (4) Program <br />Administration-includes oversight, staff training and reports, service provider <br />arrangements, and non-disclosure of specific practices. <br />B. Identity Theft Prevention Program for the City <br />FACTA requires that the City adopt an Identity Theft Prevention Program <br />before May 1, 2009. The Program being recommended for the City to adopt covers <br />all the necessary actions that the City must take in order to be in compliance with <br />FACTA. It addresses each of the legal points referenced above and describes <br />specific steps that the City must take in order to implement a successful and effective <br />program. <br />Conclusion <br />The City is covered by the new amendment to the Fair and Accurate Credit <br />Transactions Act and should adopt a policy by May 1, 2009 in order to be in <br />compliance with the requirements of that Act. <br />" (I <br />"0L05 1 <br />