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<br />VII. PROGRAM ADMINISTRATION. <br /> <br />A. Oversight <br /> <br />Responsibility for developing, implementing and updating this Program lies with an Identity Theft <br />Committee for the Utility. The Committee Is headed by a Program Administrator who may be the head of <br />the Utility or his or her appointee. Two or more other individuals appointed by the head of the Utility or <br />the Program Administrator comprise the remainder of the committee membership. The Program <br />Administrator will be responsible for the Program administration, for ensuring appropriate training of Utility <br />staff on the Program, for reviewing any staff reports regarding the detection of Red Flags and the steps for <br />preventing and mitigating Identity Theft, determining which steps of prevention and mitigation should be <br />taken in particular drcumstances and considering periodic changes to the Program. <br /> <br />B. StatfTraining and Reports <br /> <br />Utility staff responsible for implementing the Program shall be trained either by or under the <br />direction of the Program Administrator In the detection of Red Flags, and the responsive steps to be taken <br />when a Red Flag is detected. <br /> <br />C. Service Provider Arrangements <br /> <br />In the event the Utility engages a service provider to perform an activity in connection with one or <br />more accounts, the utility will take the follOWing steps to ensure the service provider performs Its activity In <br />accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of <br />Identity Theft. <br /> <br />1. Require, by contract, that service providers have such policies and procedures in place; and <br />2. Require, by contract, that service providers review the Utility's Program and report any Red Flags <br />to the Program Administrator. <br /> <br />D. SpecifiC Program Elements and Confidentiality <br /> <br />For the effectiveness of Identity Theft prevention Programs, the Red Rag Rule envisions a degree <br />of confidentiality regarding the Utility's spedflc practices relating to Identity Theft detection, prevention <br />and mitigation. Therefore, under this Program, knowledge of such specific practices are to be limited to <br />the Identity Theft Committee and those employees who need to know them for purposes of preventing <br />Identity Theft. Because this Program is to be adopted by a public body and thus publicly available, it <br />would be counterproductive to list these specific practices here. Therefore, only the Program's general red <br />flag detection, Implementation and prevention practices are listed in this document. <br /> <br />6 <br />