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<br />V. PREVENTING AND MmGAllNG IDENTITY THEFT <br /> <br />In the event Utility personnel detect any identified Red Flags, such personnel shall take one or <br />more of the following steps, depending on the degree of risk posed by the Red Flag: <br /> <br />Prevent and Mitiaate <br /> <br />1. Continue to monitor an account for evidence of Identity Theft; <br />2. Contact the customer; <br />3. Change any passwords or other security devices that permit access to accounts; <br />4. Not open a new account; <br />5. Close an existing account; <br />6. Reopen an account with a new number; <br />7. Notify the Program Administrator for determination of the appropriate step(s) to take; <br />8. Notify law enforcement; or <br />9. Determine that no response is warranted under the particular circumstances. <br /> <br />Protect customer identifvlna information <br /> <br />In order to further prevent the likelihood of identity theft occurring with respect to Utility accounts, <br />the Utility will take the following steps with respect to its internal operating procedures to protect customer <br />identifying information: <br /> <br />1. Ensure that its webslte is secure or provide clear notice that the website is not secure; <br />2. Ensure complete and secure destruction of paper documents and computer flies containing <br />customer information; <br />3. Ensure that office computers are password protected and that computer screens lock after a set <br />period of time; <br />4. Keep offices clear of papers containing customer information; <br />5. Request only the last 4 digits of social security numbers (if any); <br />6. Ensure computer virus protection is up to date; and <br />7. Require and keep only the kinds of customer information that are necessary for utility purposes. <br /> <br />VI. PROGRAM UPDATES <br /> <br />This Program will be periodically reviewed and updated to reflect changes in risks to customers <br />and the soundness of the Utility from Identity Theft. At least rrnserttime: everY 6 months. vear. etc.'. the <br />Program Administrator will consider the Utility's experiences with Identity Theft situation, changes in <br />Identity Theft methods, changes in Identity Theft detection and prevention methods, changes in types of <br />accounts the Utility maintains and changes in the utility's business arrangements with other entitles. After <br />considering these factors, the Program Administrator will determine whether changes to the Program, <br />Including the listing of Red Flags, are warranted. If warranted, the Program Administrator will update the <br />Program or present the fUtility Commission OR Oty Coundll with his or her recommended changes and the <br />[utilitv Commission OR City Councli] will make a determination of whether to accept, modify or reject those <br />changes to the Program. <br /> <br />5 <br />