TITLE
Recommendation to adopt resolution approving the existing Identity Theft Prevention Program in compliance with the Fair and Accurate Credit Transaction (FACT) Act. (Citywide)
DISCUSSION
In accordance with the FACT Act adopted by the federal government, the Federal Trade Commission (FTC) has set "Red Flag" rules requiring that every creditor establish a written program providing for the detection of Red Flags that could be related to identity theft. Any private or public entity that extends credit to customers by first providing goods or services and then billing for them at a later date is subject to these requirements.
As a municipal service provider, the City is considered a creditor since it provides various services such as gas, water and ambulance transport services and bills for these services after they have been rendered.
Along with all other municipal utility providers in the nation, the City is required to formally adopt its Identity Theft Prevention Program (Program) by August 1, 2009.
The Program complies with FTC requirements and provides security for our utility customers.
The Program sets forth in writing the identity protection practices that the City has followed for many years, namely:
1. Identifying relevant patterns, practices and specific activities (referred to in the program as "Red Flags") that signal possible identity theft relating to information maintained in the City's customer accounts, both those currently existing and those accounts to be established in the future.
2. Detecting "Red Flags."
3. Responding promptly and appropriately to detected "Red Flags" to prevent or mitigate identity theft relating to the City's customer account information.
4. Ensuring that the program is updated periodically to reflect any necessary changes.
This matter was reviewed by Deputy City Attorney Richard Anthony on May 19, 2009 and Budget and Performance Management Bureau Manager David Wodynski on May 20, 2009.
TIMING CONSIDERAT...
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