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FACT Act Identity Theft Prevention Program am Summary IDFederal regulations require the City of Eden Prairie ("City") to establish an Identity Theft Prevention Program ("Program"), designed to detect, prevent, and mitigate identity theft. The Program must include the identification of Red Flags that are relevant to the City's customer accounts, the detection of Red Flags, and the mitigation of and/or response to detected Red Flags. The following Program is to be administered by the FACT Act Officer, which is designated as the Finance Manager of the City. rThe FACT Act Officer shall see that the appropriate personnel receive training to properly implement the Program. - - _ i - .. . - .. . . . • _ _ _. . - . . ► • •: - • . inally, the FACT Act Officer shall periodically reassess the City's risks of identity theft and the ability of Program to address that identity theft and, if necessary, modify the Program. I. Definitions A "Red Flag" means a pattern, practice, or specific activity that indicates the possible existence of identity theft. Al A "covered account" means a continuing relationship established by a person for personal, family, household or business purposes that involves or is designed to permit multiple payments or transactions. "Identity Theft" means a fraud committed or attempted using the identifying information of another person without authority. "Service provider"means a third party that provides a service directly to, or behalf of the City. II. Identifying Relevant Red Flags The City will consider the following risk factors in identifying relevant Red Flags for its covered accounts, as appropriate: 1. The types of covered accounts it offers or maintains; 2. The methods it provides to open its covered accounts; 3. The methods it provides to access its covered accounts; and 4. Its previous experiences with identity theft. The City will incorporate Red Flags from sources such as: 1. Incidents of identity theft that the City has experienced; 2. Methods of identity theft that the City has identified that reflect changes in identity theft risks; and, • 3. Applicable supervisory guidance. The Categories of Red Flags will include but are not limited to: