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(b) In the event City staff detect one or more Red Flags, staff may take one or more <br />of the following actions, depending on the degree of risk that the Red Flag <br />indicates identity theft: <br />1. Continue to monitor a covered account for evidence of identity theft; <br />2. Contact the customer; <br />3. Change any passwords, security codes, or other security devices that <br />permit access to a covered account; <br />4. Reopen a covered account with a new account number; <br />5. Decline to open a new covered account; <br />6. Close an existing covered account; <br />7. Not attempt to collect on a covered account or not refer a covered account <br />to a debt collector; <br />8. Notify law enforcement; or <br />9. Determine that no response is warranted under the particular <br />circumstances. <br />(c) The head of each department, or the department head's designee, shall be <br />responsible for implementation of the Program for his or her department. The <br />City Manager will periodically update the Program (including the Red Flags <br />determined to be relevant) to reflect changes in risks to customers or the City <br />from identity theft, based on factors such as: <br />1. The experiences of the City with identity theft; <br />2. Changes in methods of identity theft; <br />3. Changes in methods to detect, prevent, and mitigate identity theft; <br />4. Changes in the types of accounts that the City offers or maintains; and <br />5. Changes in the business arrangements of the City, including service <br />provider arrangements. <br />(d) Each department head shall report to the City Manager by December 31st of each <br />year, beginning in 2010, on his or her department's compliance with the Program. <br />The report should address: <br />1. The covered accounts overseen or maintained by the department; <br />2. The effectiveness of the Program in addressing the risk of identity theft in <br />connection with the opening of covered accounts and with respect to <br />existing covered accounts; <br />3. Service provider arrangements; <br />4. Significant incidents involving identity theft and the department's <br />response; <br />. 5. Steps taken by the department to protect personal information; and <br />6. Recommendations for changes to the Program. <br />(e) If a department does not oversee any covered accounts, the annual report to the <br />City Manager may be limited to addressing steps taken by the department to <br />protect personal information. <br />(6) Oversight of service provider arrangements. Whenever the City engages a service <br />provider to perform an activity in connection with one or more covered accounts the City <br />will take steps to ensure that the activity of the service provider is conducted in <br />Administrative Order -- Page 6 of 7 <br />