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• VI. PROGRAM UPDATES <br /> This Program will be periodically reviewed and updated to reflect changes in risks to <br /> customers and the soundness of the Utility from Identity Theft. Whenever changing billing <br /> methods, changing customer data collection, or violation trends indicate a possible need for <br /> revision, the Program Administrator will consider the City's experiences with Identity Theft <br /> situation, changes in Identity Theft methods, changes in Identity Theft detection and prevention <br /> methods, changes in types of accounts the City maintains and changes in the City's business <br /> arrangements with other entities. After considering these factors, the Program Administrator will <br /> determine whether changes to the Program, including the listing of Red Flags, are warranted. If <br /> warranted, the Program Administrator will update the Program or present the Committee with his <br /> or her recommended changes and the Committee will make a determination of whether to accept, <br /> modify or reject those changes to the Program. <br /> VII. PROGRAM ADMINISTRATION. <br /> A. Oversight <br /> Responsibility for developing, implementing and updating this Program lies with an <br /> Identity Theft Committee for the City. The Committee is headed by a Program Administrator <br /> who may be the head of the City or his or her appointee. Two or more other individuals <br /> appointed by the head of the City or the Program Administrator comprise the remainder of the <br /> committee membership. The Program Administrator will be responsible for the Program <br /> administration, for ensuring appropriate training of City staff on the Program, for reviewing any <br /> staff reports regarding the detection of Red Flags and the steps for preventing and mitigating <br /> Identity Theft, determining which steps of prevention and mitigation should be taken in <br /> particular circumstances and considering periodic changes to the Program. <br /> B. Staff Training and Reports <br /> City staff responsible for implementing the Program shall be trained either by or under <br /> the direction of the Program Administrator in the detection of Red Flags, and the responsive <br /> steps to be taken when a Red Flag is detected. <br /> • <br /> 6 <br />