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accordance with reasonable policies and procedures designed to detect, prevent, and <br />mitigate the risk of identity theft. <br />(7) Verifyin~ Information in Consumer Reports. <br />(a) If the City receives a notice of address discrepancy from a consumer reporting <br />agency, city staff will take reasonable steps to verify that the consumer report <br />relates to the consumer about whom the City has requested the report. Those <br />steps may include: <br />1. Comparing the information in the consumer report with information the <br />City: <br />a. Obtains and uses to verify the consumer's identity; <br />b. Maintains in its own records, such as applications, change of <br />address notifications, other customer account records; or <br />c. Obtains from third-party sources. <br />2. Verifying the information in the consumer report provided by the <br />consumer reporting agency with the consumer. <br />(b) After taking reasonable steps to verify the consumer's address, the City shall <br />furnish an address for the consumer that the City has reasonably confirmed is <br />accurate to the consumer reporting agency if city staff: <br />1. Can form a reasonable belief that the consumer report relates to the <br />consumer about whom the City requested the report; <br />2. Have established a continuing relationship with the consumer; and <br />3. Regularly and in the ordinary course of business furnish information to the <br />consumer reporting agency from which the notice of address discrepancy <br />relating to the consumer was obtained. <br />(c) The City will furnish the consumer's address that city staff have reasonably <br />confirmed is accurate to the consumer reporting agency as part of the information <br />it regularly furnishes for the reporting period in which it establishes a relationship <br />with the consumer. <br />Dated this ~ g~day of November, 2009. <br />_____._~r~~ <br />Jon R. Ruiz <br />City Manager <br />Administrative Order -- Page 7 of 7 <br />