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• Summary <br /> Federal regulations require the City of Arden Hills("City")to establish an Identity Theft Prevention <br /> Program ("Program"), designed to detect, prevent, and mitigate identity theft. The Program must <br /> include the identification of Red Flags that are relevant to the City's customer accounts, the <br /> detection of Red Flags,and the mitigat.• • : . • •onse to detected Red Flags.The following <br /> Program is to be administered by t ich is designated as the Finance Manager <br /> of the City. The FACT Act Officer s a see at the appropriate personnel receive training to <br /> properly implement the Program. Finally, the F CT Act Officer shall periodically reassess the <br /> City's risks of identity theft and the ability oft-tProgr. to address that identity theft and,ifnecessary, <br /> modify the Program. A^ <br /> I. Definitions <br /> A"Red Flag"means a pattern, practice, or specific activity that indicates the possible existence of <br /> identity theft. <br /> A"covered account"means a continuing relationship established by a person for personal, family, <br /> household or business purposes that involves or is designed to permit multiple payments or <br /> transactions. <br /> "Identity Theft"means a fraud committed or attempted using the identifying information of another <br /> person without authority. <br /> "Service provider"means a third party that provides a service directly to,or behalf of the City. <br /> II. Identification of Red Flags <br /> In order to identify relevant Red Flags, the City considers the types of accounts that it offers and <br /> maintains, the methods it provides to open its accounts, the methods it provides to access its <br /> accounts, and its previous experiences with Identity Theft. The City identifies the following red <br /> flags, in each of the listed categories: <br /> A. Suspicious Documents <br /> Red Flags <br /> 1. If presented, identification document or card that appears to be forged, altered or <br /> inauthentic; <br /> 2. If presented, identification document or card on which a person's photograph or <br /> physical description is not consistent with the person presenting the document; <br /> and <br /> 3. If presented, other document with information that is not consistent with existing <br /> • customer information ( ' <br /> • <br />