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B,ackg,round The purpose of the Identify Theft Protection Program (Program) is to demonstrate compliance with the Federal Trade Commission's (FTC) Identity Theft Red Flag Rule. The Rule requires creditors, including municipal utility providers, to develop an "Identity Theft Prevention Program Municipal utility providers meet the FTC's definition of a creditor because we provide services (water and sewer) up front with the intent to collect monies at a later date, Because we collect monies aft er we provide the service, we are in effect extending credit to each utility customer - albeit for a short period of time. The primary purpose of the Red Flag Rule is to protect against the establishment of false accounts and ensure existing accounts are not being manipulated. This regulation does not address or require municipal utilities to adopt measures that will fully protect consumer information and prevent unauthorized access. However, implementation of industry best practices to protect personal consumer data can prevent identity theft. The Program is intended to identify red flags that will alert employees when utility accounts are created or modified using false information, and to provide measures to respond to these events. The City's Finance Director is responsible for managing this program under the direction of the City Manager and City Council. Risk Assessment The City of Roseville has conducted an internal risk assessment to evaluate the level of risk that our current procedures might allow individuals to create fraudulent utility accounts or manipulate current (existing) accounts. This risk assessment reviewed how accounts were created and modified and the methods used to access account information. Using this information, the City of Roseville identified the following circumstances that have the potential for identify theft: • Requests to create/modify utility accounts either in person or through electronic communications. • Requests to access utility information either in person or through electronic communications. To mitigate these risks, the City of Roseville has adopted a number of red flags to detect potential fraud regarding the City's utility accounts. These red flags are not intended to be all- inclusive and other suspicious activity may be investigated as necessary. They include: • Fraud alerts or Notice of a credit freeze produced by consumer reporting agencies • Notice of other discrepancies provided by consumer reporting agencies, such as: a) Address discrepancies b) Recent and significant increases in the volume of inquiries or credit applications c) A material change in use of credit d) Account closure for cause or abuse • Inability of the customer to produce personal identification documents