|Executive Director of Information and Educational Technologies and Chief Information Officer
|Responsible Executive Officer:
|Vice President for Business & Finance
Walters State Community College enacts this program in an effort to detect, prevent and mitigate identity theft, and to help protect the institution’s faculty, staff, students and other applicable constituents from damages related to the loss or misuse of identifying information due to identity theft.
I. Identity Theft Prevention Program/Program Adoption
Walters State Community College “WSCC” established the Information Protection Committee (“IPC”) to develop an Identity Theft Prevention Program (“Program”) pursuant to the Federal Trade Commission’s Red Flags Rule, which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003 and Tennessee Board of Regents “TBR” Policy 4:01:05.60 (Identity Theft Prevention Policy). After consideration of the size and complexity of WSCC’s operations and account systems, and the nature and scope of the WSCC’s activities, the Executive Council determined that this Program was appropriate for WSCC, and therefore approved this Program on February 1, 2010 .
II. Purpose And Scope Of This Policy
WSCC recognizes that the risk to the institution and its faculty, staff, students and other applicable constituents from data loss and identity theft is a significant concern and that reasonable efforts should be made to detect, prevent, and mitigate identity theft.
- Covered account includes
- Any account that involves or is designated to permit multiple payments or transactions; or
- Any other account maintained by the Institution for which there is a reasonably foreseeable risk of identity theft to students, faculty, staff or other applicable constituents, or for which there is a reasonably foreseeable risk to the safety or soundness of the Institution from identity theft, including financial, operational, compliance, reputation or litigation risks.
- Identifying information - is any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including but not limited to: name, address, telephone number, social security number, date of birth, government issued driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, computer Internet Protocol address or routing code, credit card number or other credit card information.
- Identity theft - means a fraud committed or attempted using the identifying information of another person without authority.
- Red flag - is a pattern, practice or specific activity that indicates the possible existence of identity theft.
IV. Identification of Red Flags
- The following examples of red flags are potential indicators of fraud or identity theft. The risk factors for identifying relevant red flags include the types of covered accounts offered or maintained; the methods provided to open or access covered accounts; and, previous experience with identity theft. Any time a red flag or a situation closely resembling a red flag apparent, it should be investigated for verification.
- Alerts, notifications or warnings from a credit or consumer reporting agency. Examples of these red flags include the following:
- A report of fraud or active duty alert in a credit or consumer report
- A notice of credit freeze from a credit or consumer reporting agency in response to a request for a credit or consumer report;
- A notice of address discrepancy in response to a credit or consumer report request; and,
- A credit or consumer report indicates a pattern of activity inconsistent with the history and usual pattern of activity of an applicant such as:
- A recent and significant increase in the volume of inquiries
- An unusual number of recently established credit relationships;
- A material change in the use of credit, especially with respect to recently established credit relationships; or
- An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
- Suspicious documents. Examples of these red flags include the following:
- Documents provided for identification that appears to have been altered, forged or are inauthentic.
- The photograph or physical description on the identification document is not consistent with the appearance of the individual presenting the identification.
- Other information on the identification is not consistent with information provided by the person opening a new covered account or individual presenting the identification.
- Other information on the identification is not consistent with readily accessible information that is on file with the Institution, such as a signature card or a recent check.
- An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
- Suspicious personal identifying information. Examples of these red flags include the following:
- Personal identifying information provided as inconsistent when compared against other sources of information used by the Institution. For example:
- The address does not match any address in the consumer report, or
- The social Security number (SSN) had not been issued or is listed on the Social Security Administration’s Death Master List.
- Personal identifying information provided by the individual is not consistent with other personal identifying information provided by that individual. For example:
- There is a lack of correlation between the SSN range and the date of birth.
- Personal identifying information provided is associated with known fraudulent activity. For example:
- The address on an application is the same as the address provided on a fraudulent application; or,
- The phone number on an application is the same as the number provided on a fraudulent application.
- Personal identifying information provided is of a type commonly associated with fraudulent activity. For example:
- The address on an application is fictitious, a mail drop, or a prison; or
- The phone number is invalid or is associated with a pager or answering service.
- The social security number provided is the same as that submitted by another person opening an account.
- The address or telephone number provided is the same as or similar to the address or telephone number submitted by that of another person.
- The individual opening the covered account fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
- Personal identifying information provided is not consistent with personal identifying information that is on file with the Institution.
- When using security questions (mother’s maiden name, pet’s name, etc.), the person opening that covered account cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.
- Unusual use of, or suspicious activity related to, the covered account. Examples of these red flags include the following:
- Shortly following the notice of a change of address for a covered account, the Institution receives a request for a new, additional, or replacement card, or for the addition of authorized users on the account.
- A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example:
- Nonpayment when there is no history of late or missed payments;
- A material change in purchasing or usage patterns.
- A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors).
- Mail sent to the individual is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the individual’s covered account.
- The Institution is notified that the individual is not receiving paper account statements.
- The Institution is notified of unauthorized charges or transactions in connection with an individual’s covered account.
- The Institution receives notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the Institution.
- The Institution is notified by an employee or student, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.
- A breach in the Institution’s computer security system.
V. Detecting Red Flags
- Student enrollment. In order to detect red flags associated with the enrollment of a student, the Institution will take the following steps to obtain and verify the identity of the individual opening the account:
- Require certain identifying information such as name, date of birth, academic records, home address or other identification; and,
- Verify the student’s identity at the time of issuance of the student identification card through review of driver’s license or other government-issue photo identification.
- Existing accounts. In order to detect red flags associated with an existing account, the Institution will take the following steps to monitor transactions on an account:
- Verify the identification of students if they request Information;
- Verify the validity of requests to change billing addresses by mail or email, and provide the student a reasonable means of promptly reporting incorrect billing address changes; and,
- Verify changes in banking information given for billing and payment purposes.
- Consumer/Credit Report Requests. In order to detect red flags for an employment or volunteer position for which a credit or background report is sought, the Institution will take the following steps to assist in identifying address discrepancies:
- Require written verification from any applicant that the address provided by the applicant is accurate at the time the request for the credit report is made to the consumer reporting agency; and
- In the event that notice of an address discrepancy is received, verify that the credit report pertains to the applicant for whom the requested report was made and report to the consumer reporting agency an address for the applicant that the Institution has reasonably confirmed is accurate.
VI. Responding to Red Flags
- Once a red flag or potential red flag is detected, the Institution must act quickly with consideration of the risk posed by the red flag.
- The Institution should quickly gather all related documentation, write a description of the situation and present this information to the Program Administrator for determination.
- The Program Administrator (see Section VI) will complete additional authentication to determine whether the attempted transaction was fraudulent or authentic.
- The Institution may take the following steps as is deemed appropriate:
- Continue to monitor the covered account for evidence of identity theft;
- Contact the student or applicant for which a credit report was run;
- Change any passwords or other security devices that permit access to covered accounts;
- Close and reopen the account;
- Determine not to open a new covered account;
- Provide the student with a new student identification number;
- Notify law enforcement;
- Determine that no response is warranted under the particular circumstances;
- Cancel the transaction.
VII. Protecting Personal Information
- In order to prevent the likelihood of identity theft occurring with respect to covered accounts, the Institutions may take the following steps with respect to its internal operating procedures:
- Lock file cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with covered account information when not in use.
- Lock storage rooms containing documents with covered account information and record retention areas at the end of each workday or when unsupervised.
- Clear desks, workstations, work areas, printers and fax machines, and common shared work areas of all documents containing covered account information when not in use.
- Documents or computer files containing covered account information will be destroyed in a secure manner. Institution records may only be destroyed in accordance with the Board’s records retention guideline, TBR Guideline G-070 Disposal of Records.
- Ensure that office computers with access to covered account information are password protected.
- Ensure that computer virus protection is up to date.
- Avoid the use of social security numbers.
- Utilize encryption devices when transmitting covered account information.
- Institutional personnel are encouraged to use common sense judgment in securing covered account information to the proper extent.
- Furthermore, this section should be read in conjunction with the Family Education Rights and Privacy Act (“FERPA”), the Tennessee Public Records Act, and other applicable laws and policies.
- If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact his/her supervisor. The Office of the General Counsel may be contacted for advice.
VIII. Program Administration and Oversight
Responsibility for developing, implementing and updating the Program lies with the IPC which is headed by the Program Administrator, the Assistant Vice President for Information and Educational Technologies. The Program Administrator, in consultation with the IPC, is responsible for:
- ensuring appropriate training of WSCC staff
- reviewing any staff reports regarding the detection of red flags and the steps for preventing and mitigating identity theft
- determining which steps of prevention and mitigation should be taken in particular circumstances, and
- updating the Program as necessary to remain up to date and applicable
TBR policies and guidelines are accessible online at www.tbr.edu