Identity Theft Prevention Program
Click here to download a MS Word file.
A training course for Identity Theft Prevention is also available in Blackboard and is accessible by faculty and staff.
The purpose of the Program is to detect, prevent and mitigate identity theft in connection with any covered account.
As a best practice and using as a guide the Federal Trade Commission's ("FTC") Red Flags Rule, implementing Section 114 of the Fair and Accurate Credit Transactions Act of 2003, The University of North Carolina at Pembroke ("University") developed and approved this Identity Theft Prevention Policy (Program) on August 7, 2009. The policy is available at http://www.uncp.edu/doit/policies/policy_ch01.html
"Identifying Information" means 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:
- 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
- individual identification number**
- bank or other financial account routing code
UNCP Faculty and Staff are expected to take the following actions to prevent Identity Theft:
- Require and keep only the kinds of individual information necessary for University purposes in accordance with UNCP guidelines.
- Avoid unnecessary use of social security numbers;
- Physical security will be maintained over documents containing Identifying Information related to covered accounts. Examples include keeping offices locked after hours and locking rooms and files when staff members are not present.
- Desks, workstations, work areas, printers and fax machines, and common shared work areas will be cleared of all documents containing Identifying Information when not in use.
- Whiteboards, dry-erase boards, writing tablets, and other writing surfaces in common shared work areas, which contain identifying information, will be erased, removed, or shredded when not in use.
- Ensure complete and secure destruction of paper documents and computer files containing individual account information in accordance with UNCP guidelines; when documents containing Identifying Information are discarded, they must be shredded timely.
- Ensure that office computers with access to Covered Account information are password protected;
- Ensure that laptops are password protected;
- Ensure that Websites providing access to covered accounts are secure;
- Ensure that transmission of information is limited and encrypted when necessary;
- Ensure computer virus protection is up to date; and
- DoIT 01 07 - Electronic Information Management and Security Policy states that all University electronic data must be collected, processed, stored, used and distributed in a manner that complies with applicable federal and state law as well as accepted industry standards and practices. Insofar as possible, University electronic data must be accurate, complete and reliable. University electronic data must be kept secure and stored in a controlled location.
UNCP Faculty and Staff should take the following steps to obtain and verify the identity of the person requesting services for the applicable areas:
- Student Enrollment
- Require certain Identifying Information such as name, date of birth, academic records, home address or other identification; and
- Verify the individual's identity at time of issuance of individual identification card (review of driver’s license or other government-issued photo identification).
- Verify the identification of individuals if they request information (in person, via telephone, via facsimile, via email);
- Verify the validity of requests to change billing addresses by mail or email and provide the individual a reasonable means of promptly reporting incorrect billing address changes; and
- Verify changes in banking information given for billing and payment purposes.
Credit and background reports
- 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 University has reasonably confirmed is accurate.
UNCP Faculty and Staff should be on the alert for the following Identity Red Flags in each of the listed categories:
- Notifications and Warnings from Consumer Reporting Agencies
- Report of fraud accompanying a credit report;
- Notice or report from a credit agency of a credit freeze on an applicant;
- Notice or report from a credit agency of an active duty alert for an applicant;
- Receipt of a notice of address discrepancy in response to a credit report request; and
- Indication from a credit report of activity that is inconsistent with an applicant's usual pattern or activity.
- Identification document or card that appears to be forged, altered or inauthentic;
- Identification document or card on which a person's photograph or physical description is not consistent with the person presenting the document;
- Other document with information that is not consistent with existing individual information; and
- Application for service that appears to have been altered or forged.
Suspicious Personal Identifying Information
- Identifying Information presented that is inconsistent with other information the individual provides (example: inconsistent birth dates);
- Identifying Information presented that is inconsistent with other sources of information (example: an address not matching an address on a loan application);
- Identifying Information presented that is the same as information shown on other applications that were found to be fraudulent;
- Identifying Information presented that is consistent with fraudulent activity (examples: an invalid phone number or fictitious billing address);
- Social security number presented that is the same as one given by another individual;
- A person fails to provide complete personal Identifying Information on an application when reminded to do so; and
- A person's Identifying Information is not consistent with the information that is on file for the individual.
Suspicious Covered Account Activity
- Change of address for an account followed by a request to change the individual’s name;
- Payments stop on an otherwise consistently up-to-date account;
- Account used in a way that is not consistent with prior use;
- Mail sent to the customer is returned repeatedly as undeliverable, although the customer continues to accrue changes on the covered account;
- Notice to the University that an account has unauthorized activity;
- Breach in the University's computer system security; and
- Unauthorized access to or use of individual account information.
Alerts from Others
- Notice to the University from an individual, 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.
If you detect a potentially fraudulent activity notify your supervisor immediately, then follow your department's protocol. Protocol actions may include one or more of the following:
- Canceling the transaction;
- Notifying and cooperating with appropriate law enforcement;
- Determining the extent of liability of the University; and
- Notifying the actual individual upon whom fraud has been attempted.
- Continue to monitor a Covered Account for evidence of Identity Theft;
- Contact the individual or applicant (for which a credit report was run);
- Change any passwords or other security devices that permit access to Covered Accounts;
- Refuse to open a new Covered Account;
- Provide the individual with a new individual identification number;
- Notify the Committee for determination of the appropriate step(s) taken or that need to be taken;
- Notify law enforcement;
- File or assist in filing a Suspicious Activity Report ("SAR") with the Financial Crimes Enforcement Network, United States Department of the Treasury or other relevant law enforcement agency; or
- Determine that no response is warranted under the particular circumstances
The departmental supervisor must gather all related documentation, write a description of the situation, and report the information to University Legal Counsel promptly if the fraudulent activity is a major and continuing threat, or at least annually if the fraudulent activity is not a major or continuing threat.
Thursday, July 1, 2010