Identity Theft Prevention

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; and
5. Indication from a credit report of activity that is inconsistent with an applicant’s usual pattern or activity.

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

1. Identifying Information presented that is inconsistent with other information the individual provides (example: inconsistent birth dates);
2. Identifying Information presented that is inconsistent with other sources of information (example: 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 (examples: an invalid phone number or fictitious billing address);
5. Social security number presented that is the same as one given by another individual;
6. A person fails to provide complete personal Identifying Information on an application when reminded to do so; and
7. A person’s Identifying Information is not consistent with the information that is on file for the individual.

1. Change of address for an account followed by a request to change the individual’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 individual is repeatedly returned as undeliverable;
5. Notice to the University that an individual 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; and
8. Unauthorized access to or use of individual account information.

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.

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

1. Require certain Identifying Information such as name, date of birth, academic records, home address or other identification; and
2. Verify the individual’s identity at time of issuance of individual identification card (review of driver’s license or other government-issued photo identification).

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

1. Verify the identification of individuals 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 individual a reasonable means of promptly reporting incorrect billing address changes; and
3. Verify changes in banking information given for billing and payment purposes.

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 shall 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; and
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.

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. Refuse to open a new Covered Account;
5. Provide the individual with a new individual identification number;
6. Notify the Committee for determination of the appropriate step(s) taken or that need to be taken;
7. Notify law enforcement;
8. 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
9. Determine that no response is warranted under the particular circumstances.

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 individual Identifying Information:

1. Ensure that websites providing access to covered accounts are secure;
2. Ensure complete and secure destruction of paper documents and computer files containing individual account information in accordance with UNCG records retention guidelines;
3. Ensure that office computers with access to Covered Account information are password protected;
4. Ensure that laptops are password protected;
5. Avoid unnecessary use of social security numbers;
6. Ensure the security of the physical facility that contains Covered Account information;
7. Ensure that transmission of information is limited and encrypted when necessary;
8. Ensure computer virus protection is up to date; and
9. Require and keep only the kinds of individual information that are necessary for University purposes in accordance with UNCG records retention guidelines.
10. University Policy requires that data that is classified as Restricted in the Data Classification Policy be stored on ITS network storage facilities, not on local hard drives or media.

This Program incorporates by reference the following internal policies and procedures:

Information Technology Services policies concerning computer use and electronic records are located at the following URL http://its.uncg.edu/Technology_Policies/ and are incorporated in this policy by reference.

Responsibility for developing, implementing and updating this Program lies with the Identity Theft Prevention Committee (“the Committee”). The members of the Committee shall be determined by the Chancellor or another senior administrator designated by the Chancellor. The Committee shall be responsible for reviewing any University staff reports regarding the detection of Red Flags and the steps for preventing and mitigating Identity Theft, and considering periodic changes to the Program.

The management of those departments responsible for covered accounts will insure that staff playing a key role in identifying, detecting, resolving and reporting identity theft are appropriately trained and updated as necessary in the detection of Red Flags and the responsive steps to be taken when a Red Flag is detected.

The Management of those departments responsible for covered accounts shall report to the Committee at least annually on compliance by the University with this Program. The report shall address matters such as the effectiveness of the policies and procedures of the University in addressing the risk of Identity Theft in connection with the opening of Covered Accounts and with respect to existing Covered Accounts; Service Provider arrangements; significant incidents involving Identity Theft and the University’s response; and recommendations for material changes to the Program.

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 reasonable policies and procedures designed to detect, prevent and mitigate the risk of Identity Theft.

Require, by signed contract, that Service Providers agree to comply with all applicable federal, state and local statutes, rules and regulations, or similar language.