1.4.1 Procedures for University Identify Theft Prevention Program and Red Flags Identification, Detection and Response

I. Introduction

The following Procedures are established under the University Identity Theft Prevention Program Policy (“Policy”) and apply to the Illinois State University Identity Theft Prevention Program (“Program”). It is the responsibility of all Administrators, Deans, Directors, Department Heads, Fiscal Agents and Data Custodians to ensure compliance with these Procedures and the Program as established by the Policy.

University areas specifically identified as falling within the Red Flags criteria are listed below; however, this list is not exhaustive and there may be other offices to which the Red Flag rules apply. Offices required to comply with the Red Flags criteria include but are not limited to:

• Redbird Card Office
• Payroll
• Student Accounts
• Cashiers
• Collections
• Financial Aid
• Health Services
• Human Resources
• University Registrar

II. Definitions

“Identity Theft” is 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.

“Creditor” is any person who defers payments for services rendered, such as an organization that bills at the end of the month for services rendered the previous month.

“Covered Account” includes all accounts or loans that are administered by the University that involve multiple payments or transactions such as a loan that is billed monthly throughout the semester rather than requiring full payment at the beginning of the semester.

“Program Administrator” is the individual designated by this policy with primary responsibility for oversight of the University Identity Theft Prevention Program.

“Identifying information” is any name or number that may be used, alone or in conjunction with any other information, to identify a specific person.  This includes 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’s Internet Protocol address, or routing code.

III. Red Flag Rule Requirements

Under the Red Flags Rule, the University is required to establish an “Identity Theft Prevention Program” tailored to its size, complexity and the nature of its operation.  Each program must contain reasonable policies and procedures to:

1. Identify relevant Red Flags for new and existing covered accounts and incorporate those Red Flags into the Program.
2. Detect Red Flags that have been incorporated into the Program.
3. Respond appropriately to any Red Flags that are detected to prevent and mitigate identity theft.
4. Ensure the Program is updated periodically to reflect changes in risks.
5. Address continued administration of the program.

IV. Identification of Red Flags

In order to identify relevant Red Flags, the University must consider the types of accounts that it offers and maintains, methods it provides to open its accounts, methods it provides to access its accounts, and its previous experiences with identity theft. The University has identified the following Red Flags including but not limited to those listed in the following categories:

A. Notifications and Warnings from Credit Reporting Agencies            

Red Flags:

1. Report of fraud accompanying a credit report.
2. Notice or report from a credit agency of a credit freeze on an applicant.
3. Notice or report from a credit agency of an active duty alert for an applicant.
4. Receipt of a notice of address discrepancy in response to a credit report request.
5. Indication from a credit report of activity that is inconsistent with an applicant’s usual pattern or activity.
   1. A recent and significant increase in the volume of inquiries.
   2. An unusual number of recently established credit relationships.
   3. A material change in the use of credit, especially with respect to recently established credit relationships.
   4. An account that was closed for cause or identified for abuse of account privileges by a University.
   5. Indication from a credit report of activity that is inconsistent with an applicant’s usual pattern or activity.

B. Suspicious Documents

Red Flags:

1. Identification document or card that appears to be forged, altered or inauthentic.
2. Identification document or card on which an individual’s photograph or physical description is not consistent with the person presenting the document.
3. Other document with information that is not consistent with information being provided or existing information that is on file.
4. Application for service that appears to have been altered or forged.

C. Suspicious Personal Identifying Information

Red Flags:

1. Identifying information presented that is inconsistent with other information being provided (such as an inconsistent date of birth or Social Security Number).
2. Identifying information presented that is inconsistent with other sources of information (such as an address not matching an address on a loan application).
3. Identifying information presented that is the same as information shown on other applications that were found to be fraudulent.
4. Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address).
5. Social security number presented that is the same as one given by another person.
6. An address or phone number presented that is the same as that of another person.
7. A person fails to provide complete personal identifying information on an application when reminded to do so.
8. A person’s identifying information is not consistent with the information that is on file for that person.

D. Suspicious Covered Account Activity or Unusual Use of Account

Red Flags:

1. Change of address for an account followed by a request to change the person’s name.
2. Payments stop on an otherwise consistently up-to-date account.
3. Account used in a way that is not consistent with prior use.
4. Mail sent to the person is repeatedly returned as undeliverable.
5. Notice to the University that a person is not receiving mail sent by the University.
6. Notice to the University that an account has unauthorized activity;
7. Breach in the University's computer system security.
8. Unauthorized access to or use of personal account information.

E. Alerts from Others

Red Flag:

1. Notice to the University from an account holder; identity theft victim; law enforcement; or other person that the University has opened or is maintaining a fraudulent account for a person engaged in identity theft.

V. Detecting Red Flags

A. Verification of Identity

In order to detect any of the Red Flags identified above associated with the enrollment of a student or the hiring of a University employee, University personnel will take the following steps to obtain and verify the identity of the person opening the account:

Detect:

1. Require certain identifying information such as name, date of birth, academic records, home address or other identification.
2. Verify the person’s identity at time of issuance of a University identification card (review of driver’s license or other government-issued photo identification).

B. Existing Accounts

In order to detect any of the Red Flags identified above for an existing covered account, University personnel will take the following steps to monitor transactions on an account:

Detect:

1. Verify the identification of the individual if they request information (in person, via telephone, via facsimile, via email).
2. Verify the validity of requests to change billing addresses by mail or email and provide the person a reasonable means of promptly reporting incorrect billing address changes.
3. Verify changes in banking information given for billing and payment purposes.

C. Consumer ("Credit") Report Requests

In order to detect any of the Red Flags identified above for an employment or volunteer position for which a credit or background report is sought, University personnel will take the following steps to assist in identifying address discrepancies:

1. 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.
2. 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 University has reasonably confirmed is accurate.

VI. Preventing and Mitigating Identify Theft

A. Prevent and Mitigate

In the event University personnel detect any identified Red Flags, such personnel shall take one or more of the following steps, depending on the degree of risk posed by the Red Flag:

1. Continue to monitor a covered account for evidence of identity theft.
2. Contact the individual or applicant (for which a credit report was run).
3. Change any passwords or other security devices that permit access to covered accounts.
4. Not open a new covered account or close an existing covered account.
5. Not attempting to collect on a covered account or not selling a covered account to a debt collector.
6. Provide the individual with a new personal identification number.
7. Notify the program administrator for determination of the appropriate step(s) to take.
8. Notify law enforcement.
9. File or assist in filing a Suspicious Activities Report (“SAR”).
10. Determine that no response is warranted under the particular circumstances.

B. Protect Personal Identifying Information

In order to further prevent the likelihood of Identity Theft occurring with respect to covered accounts, the University will take the following steps with respect to its internal operating procedures to protect personal identifying information:

1. Ensure that its website is secure or provide clear notice that the website is not secure.
2. Ensure complete and secure destruction of paper documents and computer files containing personal account information when a decision has been made to no longer maintain such information.
3. Ensure that office computers with access to covered account information are password protected.
4. Restrict use of Social Security Numbers according to Illinois Sate University Policy 1.1.13.
5. Ensure computer virus protection is up to date.
6. Require and keep only the kinds of personal information that are necessary for University purposes.

VII. Program Administration

A. Program Oversight

Responsibility for developing, implementing and updating the University Identity Theft Prevention Program lies with the Illinois State University Identity Theft Committee. The Committee will be headed by a Program Administrator(s) who is the individual(s) designated by this policy with primary responsibility for oversight of the University Identity Theft Prevention Program. The President of the University or his or her designee will appoint the Program Administrator. Two or more other individuals appointed by the President or the Program Administrator shall comprise the remainder of the Committee membership.

The Program Administrator will be responsible for ensuring appropriate training of University staff on the Program, for 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 considering periodic changes to the Program. The University Identity Theft Committee will periodically review and update this Program to reflect changes in risks and in the soundness of the University from identity theft.

B. Staff Training and Reports

University staff responsible for implementing the Program shall be trained either by or under the direction of the Program Administrator in the detection of Red Flags and the responsive steps to be taken when a Red Flag is detected. University staff shall be trained, as necessary, to effectively implement the Program. University employees are expected to notify the Program Administrator once they become aware of an incident of identity theft or of the University’s failure to comply with this Program.

At least annually or as otherwise requested by the Program Administrator, University staff responsible for development, implementation, and administration of the Program shall report to the Program Administrator on compliance with this Program. The report should address such issues as effectiveness of the policies and procedures in addressing the risk of identity theft in connection with the opening and maintenance of covered accounts, service provider arrangements, and significant incidents involving identity theft and management’s response, and recommendations for changes to the Program.

C. Service Provider Arrangements

In the event the University engages a service provider to perform an activity in connection with one or more covered accounts, the University will take the following steps to ensure the service provider performs its activity in accordance with the policies and procedures designed to detect, prevent and mitigate the risk of identity theft.

1. Require, by contract, that service providers have such policies and procedures in place.
2. Require, by contract, that service providers review the University's Identity Theft Prevention Program and report any Red Flags to the Program Administrator or the University employee with primary oversight of the service provider relationship.

D. Non-disclosure of Specific Practices

For the effectiveness of this Identity Theft Prevention Program, knowledge about specific Red Flag identification, detection, mitigation and prevention practices may need to be limited to the Committee who develops this Program and to those employees with a need to know them. Any documents that may have been produced or are produced in order to develop or implement this program that list or describe such specific practices and the information those documents contain are to be considered “confidential” and should not be shared with others. The Program Administrator shall inform the Committee and those employees with a need to know the information of those documents or specific practices which should be maintained in a confidential manner.