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9. Determining that no response is warranted under the particular circumstances. • V. Methods for Administering the Program The City Council is ultimately responsible for the Identity Theft Prevention Program. The FACT Act Officer is responsible for the day-to-day administration and oversight of the Program. The FACT Act Officer is expected to: 1. Assign specific responsibility for the Program's implementation; 2. Review, prepare and provide at least annually, reports on the City's compliance with the Identity Theft Prevention compliance program, the effectiveness of the policy and procedures, significant incidents involving identity theft and the City's response; and recommendations for material changes to the Program; 3. Obtain from the City Council approval of changes to the procedures and approval of policy as necessary to address changing identity theft risks; 4. Train appropriate staff in the detection of Red Flags and the responsive steps to be taken when a Red Flag is detected; and, 5. Whenever the City engages a service provider to perform an activity in connection with one or more accounts, the FACT Act Officer will ensure that the activity of the service provider is conducted in accordance with reasonable policies and procedures designed to detect, prevent, • and mitigate the risk of identity theft. For example, the City could require the service provider by contract to have policies and procedures to detect relevant Red Flags that may arise in the performance of the service provider's activities, and either report the Red Flags to the City, or to take appropriate steps to prevent or mitigate identity theft. VI. Updating the Program The City will update the Program (including the Red Flags determined to be relevant) periodically to reflect changes in risks to customers or to the safety and soundness of the City from identity theft, based on factors such as: 1. The experiences of the City with identity theft; 2. Changes in methods of identity theft; 3. Changes in methods to detect,prevent, and mitigate identity theft; 4. Changes in the types of accounts that the City offers or maintains; and, 5. Changes in the business arrangements of the City, including joint ventures, and service provider or service provider arrangements. VII. Identity Theft Prevention Program Red Flags 411 The City's Identity Theft Prevention Program will include but not be limited to the following Red Flags,which shall be updated as necessary and determined by the FACT Act Officer: