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Identity Theft Prevention Program

TBR Policy Reference: 4:01:05:60

Approved by: Bruce Blanding

Original Date Effective: 2010-12-17

Under the direction of the Federal Trade Commission and The Tennessee Board of Regents, Jackson State Community College (JSCC) enacts this Identity Theft Program in an etfort to detect, prevent and mitigate identity theft, and to help protect the Institution, faculty, staff, students ancl other applicable constituents from damages related to the loss or misuse of identifying information clue to identity theft. The program does not address the Tennessee Technology Centers and or any transactions that originate at technical institutions for which JSCC is the lead institution.

The program will:

  1. ldentify patterns, practices or specific activities ("red nags") that could indicate the existence of identity theft with regard to new or existing covered accounts;
  2. Detect red nags that are incorporated in the program;
  3. Respond appropriately to any red flags that are detected under this program to prevent and mitigate identity theft;
  4. Ensure periodic updating of the program, including reviewing the accounts that are covered and the identified red flags that are part of this program; and1
  5. Promote compliance with state and federal laws and regulations regarding identity theft protection. The program shall, as appropriate, incorporate existing TBR and institutional policies and guidelines such as anti-fraud programs and information security programs that control reasonably foreseeable risks.

SECTION 1: 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 is 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:

  1. A report of fraud or active duty alert in a credit or consumer repo1t;
  2. A notice of credit freeze from a credit or consumer repo1t1ng agency in response to a request for a credit or consumer report;
  3. A notice of address discrepancy in response to a credit or consumer report request; and,
  4. 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 identlfled for abuse at account privileges by a financial institution or creditor.

Suspicious documents. Examples of these red flags Include the fo!lowini;r

  1. Documents provided for identlfication that appear to have been altered, forged or are inauthentic,
  2. The photograph or physical description on the identification document is not consistent with the appearance of the individual presenting the identification.
  3. Other information on the identification is not consistent with Information provided by the person opening a new covered account or individual presenting the identification.
  4. 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.
  5. 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:

  1. Personal identifying information provided is Inconsistent when compared against other sources of information used by the Institution. For example:
    • The address does not match any address in the consumer repo1t; or,
    • The Social Security number (SSN) llas not been issued or is listed on the Social Security Administration's Death Master File.
  2. Persona! identifying information provided by the individual is not consistent 1Nith other personal identifying information provided by that individual. For example, there ls a lack of correlation between the SSN range and date of birth.
  3. 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 sa1ne as the number provided on a fraudulent application.
  4. Personal [dentjfying 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 assoclated with a pager or answerin9 service.
  5. The social security number provided is the same as that submitted by another person opening an account.
  6. The address or telephone number provided is the same as or similar to tile address or telephone number submitted by that of another person.
  7. The individual opening the covered account fails to provide al! required personal identifying information on an application or in response to notification that the application is incomplete.
  8. Personal identifying information provided is not consistent with personal identifying information that is on file with the Institution.
  9. 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:

  1. Shortly following the notice of a change of address for a covered account, the Institution receives a request for a new, addltional, or replacement card, or for the addition of authorized users on the account.
  2. 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.
  3. 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).
  4. Mail sent to the individual is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the individual's covered account.
  5. The Institution is notified that the individual is not receiving paper account statements.
  6. The Institution is notified of unauthorized charges or transactions in connection with an individual's covered account
  7. The Institution receives notice from customers, victims of identity theft, law enforcement autho1ities 1 or other persons regarding possible identity theft in connection with covered accounts held by the Institution.
  8. The Institution is notified by a 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
  9. A breach in the Institution's computer security system.

SECTION 2: 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:

  1. Require certain identifying information such as name1 date of birth, academic records, home address or other identification; and.
  2. Verify the student's identity at the time of issuance of the student identification card through review of driver's license or other government-issued photo identification.

Existing accounts. In order to detect red flags associated with an existing account 1 the Institution will take the following steps to monitor transactions on an account:

  1. Verify the identification of students if they request lnfonnat,011;
  2. 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,
  3. 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 repo1t is sought, the Institution 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; and
  2. In the event that notice of an address discrepancy is received, verify that the credit report retains to the applicant for whom the requested report was made and report to the consullier repo1ting agency an address for the applicant that the Institution has reasonably confirmed is accurate.

SECTION 3: RESPONDING TO RED FLAGS

Once a red flag or potential red flag is detected, the Institution must act quickly with consideration of the risk posccl 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 will complete additional authentication to determine whether the attempted transaction was fraudulent or authentlc.

Jackson State Community College may take the following steps as is deemed appropriate:

  1. Continue to monitor the covered account for evidence of identity theft;
  2. Contact the student or applicant for which a credit repo1t was run;
  3. Change any passwords or other security devices that permit access to covered accounts;
  4. Close and reopen the account;
  5. Determine not to open a new covered account;
  6. Provide the student wlth a new student identification number;
  7. Notify law enforcement;
  8. Determine that no response is warranted under the particular circurnstances.
  9. Cancel the transaction,

SECTION 4: PROTECTING PERSONAL INFORMATION

In order to prevent the likelihood of identity theft occurring with respect to covei-ed accounts, JSCC may take the following steps with respect to its internal operating procedures:

  1. Lock file cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with covered account information when not ln use.
  2. Lock storage rooms containing documents with covered account information and record retention areas at the end of each workday or when unsupervised.
  3. 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,
  4. 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.

  1. Ensure that office computers with access to covered account inforrnation are password protected.
  2. Ensure that computer virus protection is up to date.
  3. Avoid the use of social security numbers.
  4. Utilize enoyption devices when transmitting covered account information.

Jackson State Community College 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 c.ontact his/her supervisor. The Office of the General Counsel may be contacted for advice.

SECTION 5 : PROGRAM ADMINISTRATION

Oversight and Appointment of the Institutional Program Administrator Jackson State Community College has appointed the Manager of Business Services as the Program Administrator having the responsibility of oversight 1 development, implementation and administration of the program; approval and implementation of needed changes to the program; and, staff training. The Program Administrator is also responsible for ensuring that appropriate steps are taken for preventing and mitigating identity theft, for reviewing any staff reports regarding the detection of red flags, and for determining which steps should be taken in particular circumstances when red flags are suspected or detected.

The Program Administrator is responsible for submission of an annual report to Jackson State Community College's President concerning institutional compliance With and effectiveness of the program. This report should address service provider arrangements, the effectiveness of the program in addressing the risk of identity theft; significant incidents of identity theft and the institution's response; and, any recommendations for material changes to the program.

Staff training

Staff training shall be conducted for all employees for whom it is reasonably foreseeable, as determined by the Program Administrator, may come into contact with covered accounts or identifying lnformation.

Periodic Updates to the Program

At periodic intervals established in the program1 or as required, the program will be re-evaluated to determine whether all aspects of the program are up to date and applicable, Consideration will be given to Jackson State Community College's experiences with identity theft situations; changes In Identity theft methods, detection methods or prevention methods; and, changes in the Institution's business arrangernents with other entities.

Periodic reviews will include an assessment of which accounts al'e covered by the program. As part of the review, red flags may be revised, replaced or ellmlnated. Defining new red flags may also be appropriate,

Actions to take in the event that fraudulent activity ls suspected or discovered may also require revision to the program.

Overview of service provider arrangements

Jackson State Community College assumes the responsibility of ensuring that the activities of all service providers are conducted in accordance with reasonable policies and procedures designated to detect, prevent, and mitigate the risk of identity theft. In the event JSCC engages a service provider to perform an activity in connection with one or more covered accounts, the Institution will take the followlng 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.

  1. Require 1 by contract, that service providers have such policies and procedures in place; or,
  2. Require, by contract, that service providers review the Institution's program and report any red flags to the Program Adniinistrator.

Specific language for inclusion in contracts can be found in TBR Guideline G-030 Contracts and Agreements.

A service provider that maintains its own identity theft prevention program, consistent with the guidance of the red flag rules and validated by appropriate due diligence, may be considered to be meeting these requirements.

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