10-14-08 - Laserfiche WebLink

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Memo • Red Flags Rule 2 Compliance steps include 1) Assign a program administrator, 2)Appoint a Privacy Committee, 3) Develop an Identity Theft Prevention Program, 4)Approve the program by November 1, 2008, and 5)Update the program as needed. To fulfill these requirements, the Finance Director will be appointed as the program administrator, the Financial Planning and Analysis Committee along with the Accounting Clerk will be appointed as the Privacy Committee, and the City Administrator will approve the program as a senior level of management in the City. As the Privacy Committee, the Financial Planning and Analysis Committee and the Accounting Clerk will need to develop the Identity Theft Prevention Program and customize it for our use. The Accounting Clerk processes all the utility billing for the City and will be in attendance at our meeting to work with the committee. I have provided the templates developed by the MMUA and some examples that have been adopted by other utilities. We must note that it may not be necessary to use certain Identity Theft prevention techniques included in the template, as the examples in the template are taken nearly directly from the FTC provided information. We must determine what items to specifically include or exclude and which sections we need to expand. For example,we do not check credit reports, so we would want to eliminate that category; however,we may want to expand the "Prevent and Mitigate Identity Theft"sections. Our Accounting Clerk, Pang Silseth • will be better able to describe our system and then discuss with you how we should customize this program for our use. Another thing to keep in mind is that we do not want to start collecting data. Information on all utility bills except "electric bills" is public data. We do not want to start another source of information that is available to be used in identity theft. It was also brought to our attention that we may want to stay vague in our items so that we do not create liabilities for ourselves by stating that we will perform certain activities on a regular basis. I will briefly go over the attached power point presentation and our Accounting Clerk will go over the process for establishing a utility billing account and how they are maintained. We will they move on to modify the attached template for our use. RECOMMENDED ACTION: Develop an Identity Theft Prevention Program for the City of Arden Hills.