Management and Use of University Funds and Identity Theft Prevention Plan: Difference between pages

From Appalachian State University Policy Manual
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Policy 501
Policy 105.5
== Introduction ==
=== Program Adoption ===
1.1.1 As a best practice and using as a guide the Federal Trade Commission's Red Flags Rule (16 CFR Part 681, implementing Section 114 of the Fair and Accurate Credit Transactions Act of 2003, Public Law 108-159) and North Carolina General Statutes, Chapter 75, Article 2A, Appalachian State University (the "University") has developed an Identity Theft Prevention Program (the "Program") described below. This Program was developed with oversight and approval of the Board of Trustees of Appalachian State University (the "Board"). After consideration of the size and complexity of the Universitys operations and account systems, and the nature and scope of the Universitys activities, the Board determined that this Program was appropriate for the University, and approved it on September 24, 2010 (the "Effective Date").  The purpose of this Program is to detect, prevent and mitigate identity theft in connection with any covered account. This Program envisions the implementation of policies and procedures subject to the Chancellor's approval in order to achieve these goals.


== Introduction ==
== Scope ==
2.1 All University personnel whose employment duties require or allow access to identifying information of other employees or students are responsible for implementing this Program.


1.1 The Controller's Office is a division of Business Affairs primarily responsible for the recording, accounting, controlling and reporting of all University financial transactions subject to regulations and procedures established by the North Carolina Department of Administration and the North Carolina State Auditor's Office. All funds for the operation of the University's academic programs and support facilities, student aid programs, student support facilities, grant programs and any other funds directly related to the total mission of the University are administered through this office
== Definitions  ==


== Scope ==
=== "Covered Account"  ===
:any account that constitutes a continuing financial relationship or is designed to permit multiple payments or transactions between the University and a person for a service, such as extension of credit, debit cards, Perkins Loans, Federal Family Education Loan Program (FFELP), institutional loans, accounts covered by the Health Insurance Portability and Accountability Act (HIPAA), deposit accounts, scholarship accounts, student accounts, and tuition payment plans.


:any other account that the University offers or maintains for which there is a reasonably foreseeable risk to holders of the account or to the University from identity theft, such as use of consumer reports for employee background checks, credit applications and institutional debit card applications. This may include operations of utilities (e.g., New River Light & Power Company), clinical and research activities, and public service activities.


== Definitions  ==
=== Identifying Information ===
:means any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including, but not limited to:


== Policy and Procedure Statements  ==
#name
=== Office Organization ===
#address
The Office is organized into three major areas of responsibilities designated: State Funds Accounting, Special Funds Accounting, and Student Accounts. The three major areas are further divided into specific functional sections as outlined below:
#telephone number
#social security number
#date of birth
#government-issued driver's license or identification number
#alien registration number
#government passport number
#employer or taxpayer identification number
#individual identification number
#computer's Internet Protocol address
#bank or other financial account routing code


==== State Funds Accounting ====
=== Identity Theft ===
#Accounts Payable
:means a fraud committed or attempted using the identifying information of another person without authority [16 CFR 603.2(a)].
#Payroll
#General Ledger Accounting and Budget Reporting
#Current Operation Fund (Academic)
#Student Auxiliaries (Auxiliary)
#Institutional Auxiliaries (Trust Funds)  
#Debt Retirement Funds


==== Special Funds Accounting ====
=== Program Administrator ===  
#Contracts and Grants Accounting
:means the individual designated with primary responsibility for oversight of this Program.
#Capital Improvement Funds
#Special Funds
==== Student Accounts ====
#Cashier's Office
#Student Accounts Receivable
#Loans and Scholarships


'''Location''' - The Controller's Office is located in the Business Affairs Annex Building on the State Farm Road.
=== Red Flag ===
:means a pattern, practice, alert or specific activity that indicates the possible existence of identity theft.


'''Assistance''' - If your specific question is not answered in this section of the RESOURCE MANUAL, contact the Controller's Office at 262-2110.
=== Service Provider ===
:means a person or entity that provides a service directly to the University.


=== Budget Office ===
== Policy and Procedure Statements  ==


==== Responsibilities ====  
=== Identification of Red Flags ===
4.2.1.1 The Budget Office is a division of Business Affairs reporting directly to the Associate Vice Chancellor for Administration. The primary responsibility of the Budget Office is to allocate and monitor all budgeted funds appropriated by the North Carolina General Assembly as directed by the Board of Governor's of the University of North Carolina System. All allocations are subject to mandates, regulations and procedures established by the North Carolina Office of State Budget, Planning and Management in compliance with the State of North Carolina General Statutes, the Office of the President of the University of North Carolina System and the State Controller's Office. Monitoring Auxiliary and Institutional Trust Funds is a secondary responsibility.
4.1.1 In order to identify relevant red flags, the University considers the types of covered accounts it offers or maintains, the methods it provides to open its covered accounts, the methods it provides to access its covered accounts, and its previous experiences with identity theft. Red flags may be detected while implementing existing account opening and servicing procedures (example: individual identification, caller authentication, third party authorization, and address changes).


==== Location ====
4.1.2 The University identifies the following as red flags in each of the listed categories:
4.2.2.1 The office, consisting of the Budget Director, an accountant and two accounting technicians, is located in the Office of the Vice Chancellor for Business Affairs, third floor, Suite 305, Dougherty Administration Building.


==== Assistance ====
#Notifications and warnings from consumer reporting agencies
4.2.3.1 The goal of the Budget Office is to assist all areas of the University in developing a comprehensive spending plan to support the total mission of Appalachian State University. If your specific question is not answered in this section of the RESOURCE MANUAL, contact the Budget Office at (828) 262-6432.
##Report of fraud accompanying a credit report;
##Notice or report from a credit agency of a credit freeze on an applicant;
##Notice or report from a credit agency of an active duty alert for an applicant;
##Receipt of a notice of address discrepancy in response to a credit report request; and
##Indication from a credit report of activity that is inconsistent with an applicant's usual pattern or activity
#Suspicious documents
##Identification document or card that appears to be forged, altered or inauthentic;
##Identification document or card on which a person?s photograph or physical description is not consistent with the person presenting the document;
##Other document with information that is not consistent with existing individual information; and
##Application that appears to have been altered or forged.  
#Suspicious personal identifying information
##Identifying information that is inconsistent with other information the individual provides (example: inconsistent birth dates);
##Identifying information that is inconsistent with other sources of information (example: an address not matching an address on a loan application);
##Identifying information that is the same as information shown on other applications that were found to be fraudulent;
##Identifying information that is consistent with fraudulent activity (examples: an invalid phone number or fictitious billing address);
##Social security number that is the same as one given by another individual;
##An address or phone number that is the same as that of another person;
##A person fails to provide complete personal identifying information on an application when reminded to do so; and
##A person's identifying information is not consistent with the information that is on file for the individual. 
#Suspicious covered account activity
##Change of address for an account followed by a request to change the individual's name;
##Payments stop on an otherwise consistently up-to-date account;
##Account used in a way that is not consistent with prior use;
##Mail sent to the individual is repeatedly returned as undeliverable;
##Notice to the University that an individual is not receiving mail sent by the University;
##Notice to the University that an account has unauthorized activity;
##Breach in the University's computer system security; and
##Unauthorized access to or use of individual account information. 
#Alerts from others
##Notice to the University from an identity theft victim, law enforcement officer or other person that the University has opened or is maintaining a fraudulent account for a person engaged in identity theft.


4.2.3.2 Organizational Chart - Business Affairs
=== Detection of Red Flags ===


{|border = "1"
==== Student Enrollment ====
!Colspan = "6"|Chancellor
|-
!Colspan = "6"|Vice Chancellor for Business Affairs
|-
!Colspan = "6"|Adminstrative Assistant
|-
|Administration
|Physical Operations
|Auxillary Operations
|New River Light & Power
|Public Safety/University Police
|-
|Controller's Office
|Design and Construction
|Bookstore
|Accounting and Finance
|Traffic Control
|-
|Administrative Support Services
|Plant Engineering
|Food Service
|Customer Service
|Investigations
|-
|University Budget
|Plant Maintenance Suprvision
|
|Engineering and Operations
|
|-
|Systems
|Water Plant
|
|Construction and Maintenance
|
|-
|
|Administrative Services
|
|Comuter Aided Drawing
|
|-
|
|Motor Pool
|
|Information Specialist
|
|}


Organizational Chart
4.2.1.1 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:


{| border="1"style="text-align;center;"
#Require certain identifying information such as name, date of birth, academic records, home address or other identification; and
|Budget Office
#Verify the individual's identity at time of issuance of individual
|-
|Chancellor
4.2.1.2 Identification card (example: review of driver's license or other government-issued photo identification).
|-
|Vice Chancellor for Business Affairs
|-
|Associate Vice Chancellor for Administration
|-
|Budget Office
|}


=== Description of Functional Areas ===
==== New Customers or Clients ====


==== State Funds Accounting ====
4.2.2.1 In order to detect any of the red flags identified above associated with service to a new customer or client, University personnel shall take the following steps to obtain and verify the identity of the person opening the account:


4.3.1.1 The character and purpose of State Funds Accounting can best be explained by the following statements of its particular objectives, functions, and responsibilities:
#Require certain identifying information such as name, date of birth, academic records, home address or other identification; and
#Checks and reviews all procurements to insure that correct code numbers are used, that there is adequate budget amounts, and proper authorization.
#Verify the individual's identity at time of issuance of individual
#Reviews and pays all purchase orders, invoices, travel advances and reimbursements, and memo requests for payment as accurately and expediently as possible.
#Prepares and pays sales tax reports for all University reporting units.
#Prepares voucher registers and posts all accounting data from voucher registers, receipts journal, adjustments journals and registrations.
#Transmits all accounting data to the Computer Center for processing.
#Prepares and distributes monthly budget and accounting reports to the Division of State Budget.
#Prepares and distributes monthly budget and accounting reports to all University departments.
#Prepares and distributes the University payrolls.
#Prepares and submits all required payroll reports to the Internal Revenue Service, North Carolina Department of Revenue, North Carolina Public Employees Social Security System, and other agencies for which reports are generated from the Payroll System.
#Provides assistance and guidance in accounting matters for all University areas.
4.3.1.2 Distributes travel reimbursement and advance travel checks.


==== Special Funding Accounts ====
4.2.2.2 Identification card (example: review of driver's license or other government-issued photo identification).


4.3.2.1 The Special Funds Accounting section of the Controller's Office is designed to receive and account for "special" funds coming to the University which are not in direct support of the academic and auxiliary areas. The following is a list of these accounts and their functions. Most of these funds are on deposit with the State Treasurer's Office as University Trust Funds.
==== Existing Accounts ====


==== Special Grants Accounts ====
4.2.3.1 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:


4.3.3.1 These accounts are used to receive, disburse and account for all State, local, and private grants, contracts, and special programs operated by the University for the academic areas. It also includes those service awards for the University and regional community.
#Verify the identification of individuals if they request information (in person, via telephone, via facsimile, via email);
#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
#Verify changes in banking information given for billing and payment purposes.


==== Consolidated Funds ====
==== Consumer ("Credit") Report Requests ====


4.3.4.1 These accounts are necessary to account for the miscellaneous activities throughout the University which generate revenue. Some accounts in this category serve as clearing accounts for funds channeled through the University temporarily. A complete accounting system is maintained on each account.
In order to detect any of the red flags identified above in regard to 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:


==== Department of Education Funded Grants =====
#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
#In the event that notice of an address discrepancy is received, verify that the credit or background 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.


This account acts as a clearing account to receive, transfer, and account for all funds coming to the University from the Department of Education. The account receives its funds from the ACH/EFT payment method through the Department of Education Payment Management System.
=== Response to Red Flags ===


==== Health and Human Services Funded Grants ====
4.3.1 Once potentially fraudulent activity is detected, an employee must act promptly to protect individuals and the University from damages and loss. At a minimum, the employee must gather all related documentation, write a description of the situation, and present this information to the program administrator.


This account acts as a clearing account to receive, transfer, and account for all funds coming to the University from the Department of Health and Human Services. The account receives its funds through the Department of Health and Human Services centralized Payment Management System.
4.3.2 The program administrator will complete additional investigation if necessary to determine whether the attempted transaction was fraudulent or authentic.


==== Appalachian State University Endowment Fund ====
4.3.3 If a transaction is determined to be fraudulent, appropriate actions must be taken immediately. Actions may include (1) canceling the transaction; (2) notifying and cooperating with appropriate law enforcement personnel; (3) determining the extent of liability of the University; and (4) notifying the individual upon whom fraud has been attempted or whose identifying information has been subjected to a security breach.


This account is necessary to account for the funds transferred from the University Bookstore, New River Light and Power Company and Appalachian State University Foundation, Inc., to be used for student scholarships.
=== Prevention and Mitigation of Identity Theft ===


==== Advanced Tuition Deposit ====
In the event University personnel detect any identified red flags, such personnel shall take one or more of the following steps to prevent and mitigate identity theft, depending on their determination of the degree of risk posed by the red flag:


This is a holding account necessary to receive the required deposits for both housing and subsistence from students who plan on entering the University at some future date.
#Continue to monitor a covered account for evidence of identity theft; 
#Contact the individual or applicant (for whom a credit or background report was run);
#Change any passwords or other security devices that permit access to covered accounts;
#Refuse to open a new covered account;
#Provide the individual with a new individual identification number;
#Notify the program administrator for determination of the appropriate step(s) to take;
#Notify appropriate law enforcement personnel;
#File or assist in filing a Suspicious Activity Report ("SAR") with the Financial Crimes Enforcement Network, United States Department of the Treasury; and/or
#Determine that no response is warranted under the particular circumstances.  


==== Capital Improvements ====
==== Protect Identifying Information ====


This account is necessary to account for the funds from State appropriations and other sources for projects designated as a capital improvement or an expansion of the physical plant.
In order to further prevent the likelihood of identity theft occurring with respect to covered accounts, the University will take the following steps to protect individual identifying information:


Special Funds Accounting is charged with the responsibility for reporting the activity of these funds to the appropriate sources and to help assure that these funds are used in the best interest of the University and within the original intent.
#Ensure that its website is secure or provide clear notice that the website is not secure;
#Ensure complete and secure destruction of paper documents and computer files containing individual account information when a decision has been made to no longer maintain such information;
#Ensure that office computers with access to covered account information are password protected;
#Ensure that laptops are password protected and encrypted;
#Avoid use of social security numbers;
#Ensure the security of the physical facility that contains covered account information;
#Ensure that transmission of information is limited and encrypted when necessary;
#Ensure computer virus protection is up to date; and
#Require and keep only the kinds of individual identifying information that is necessary for University purposes.


==== Student Accounts ====
=== Additional Identity Theft Prevention Measures ===
==== Hard Copy Distribution ====
Each employee and contractor performing work for the University will comply with the following procedures:


The Student Accounts Section consists of the Cashier's Office and the Loans and Scholarships section.
#File cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with identifying information will be locked when not in use.
#Storage rooms containing documents with identifying information and record retention areas will be locked at the end of each workday or when unsupervised.
#Desk workstations, work areas, printers and fax machines, and common shared work areas will be cleared of all documents containing identifying information when not in use.
#Whiteboards, dry-erase boards, writing tablets, and other writing surfaces in common shared work areas will be erased, removed, or shredded when not in use.
#When documents containing identifying information are discarded, they will be placed inside a locked shred bin or immediately shredded using a mechanical cross cut or Department of Defense-approved shredding device. Locked shred bins are labeled "Confidential paper shredding and recycling."


==== Cashier's Office ====
=== Program Administration ===
==== Oversight ====
The responsibility for developing, implementing and updating this Program lies with the program administrator designated by the Chancellor. The program administrator shall be responsible for ensuring appropriate training of University staff on the Program, for reviewing any staff reports regarding the detection of red flags and the steps for preventing and mitigating identity theft, determining which steps of prevention and mitigation should be taken in particular circumstances and considering periodic changes to the Program.


#The Cashier's Office is responsible for the receipting and depositing of all University related funds. The objective is to insure that monies due to or belonging to the State are received and accounted for in a manner which assures a complete and adequate record of each transaction and assures monetary control over the receiving function.
==== Staff Training ====
#The operation of the Cashier's Office is designed to aid the University in handling receipts as required by statute and to supply necessary information to the State Treasurer and the State Disbursing Officer.
University employees responsible for implementing the Program shall be trained under the direction of the program administrator in the detection of red flags and the responsive steps to be taken when a red flag is detected.
#Student and faculty/staff accounts receivable for all charges other than Loans and Scholarships are maintained in this office.  


==== Loans and Scholarships Section ====
==== Reports ====
Appropriate staff shall report to the program administrator at least annually on compliance 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.


#This section houses and maintains all fiscal records for the NDEA/NDSL Perkins Fund, Appalachian State University Student Loan Fund, Appalachian State University Scholarship Fund, Appalachian State University Funds on Deposit, College Work Study, PELL, and S.E.O.G. programs.
==== Service Provider Arrangements ====
#In addition to the normal bookkeeping activities, Loans and Scholarships is responsible for direct contact with students, former aid recipients, collection agency representatives, Department of State Auditors, Department of Justice and program officers for the Department of Health, Education and Welfare.
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 obligations in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft, including the following:
#This section is responsible for all activities involved in issuing checks and ultimately collecting repayments.


=== Description of Budget Function ===
#Require, by signed contract, that service providers have such policies and procedures in place; and
#Require, by signed contract, that service providers review the University's Program and report any red flags to the program administrator.


The character and purpose of Budget Administration can be explained by the following statements of its objectives and functions:
==== Program Updates ====
#Coordinate and prepare the biennial Continuation Budget and Expansion Budget.
The program administrator shall review and update this Program at least annually to reflect changes in risks to individuals and the University from identity theft. In doing so, the program administrator shall consider the University's experiences with identity theft situations, changes in identity theft methods, changes in identity theft detection and prevention methods, and changes in the University's business arrangements with other entities.
#Prepare quarterly allotments for the expenditure/receipt of State Funds and submit to the Office of State Budget and Management.
#Prepare Quarterly Cash Requirement Worksheets and submit to the State Controller's Office.
#Work with all divisions of the University to distribute and maintain their budgets.
#Monitor departmental budgets to prevent over spending.
#Notify departments of any over expended/over encumbered budget pools/objects within their departmental account.
#Process all internal budget adjustments and flexibility budget revisions and maintain the Online Budget Transfer System.
#Prepare budget revisions for approval by the Office of State Budget and Management.
#Maintain the University (Payroll) Position Management System to monitor lapsed salaries and Salary reserves.  
#Prepare special reports at the request of the General Administration of the University of North Carolina System, the North Carolina General #Assembly-Fiscal Research Office, Office of State Budget and Management and other offices within the University.
#Administer State Information Processing Services (SIPS) Resource Access Control (RACF) Security.
#Establish new departmental accounts as required.
#Maintain the database of organizational structure for various reporting.


== Additional References ==
== Additional References ==
This Program incorporates by reference the following policies and procedures:
#[http://support.appstate.edu/about/computer-use-policy Policy on the Use of Computers and Data Communication]
#[http://www.nss.appstate.edu/standards/open-servers-vlan-policy Computer Systems Security Policy]
#[http://www.nss.appstate.edu/standards/remote-access-policy University Remote Access Policy]
#[http://www.nss.appstate.edu/standards/trusted-access-policy Trusted Access Policy]
#[http://www.nss.appstate.edu/standards/risk-assessment-policy Risk Assessment Policy]
#[http://www.nss.appstate.edu/standards/vpn-policy Virtual Private Network (VPN) Policy]
#[http://www.nss.appstate.edu/standards/wireless-networking-policy Wireless Networking Policy]
#[http://www.nss.appstate.edu/standards/wireless-trusted-network-policy Wireless to Trusted Network Policy]
#[https://password.appstate.edu/pswdchgform/Confidentiality_Policy.aspx Confidentiality Statement]


== Authority ==
== Authority ==


16 CFR Part 681, implementing Section 114 of the
Fair and Accurate Credit Transactions Act of 2003, Public Law 108-159
North Carolina General Statutes, Chapter 75, Article 2A


== Contact Information ==
== Contact Information ==

Revision as of 18:03, 16 May 2012

Policy 105.5

Introduction

Program Adoption

1.1.1 As a best practice and using as a guide the Federal Trade Commission's Red Flags Rule (16 CFR Part 681, implementing Section 114 of the Fair and Accurate Credit Transactions Act of 2003, Public Law 108-159) and North Carolina General Statutes, Chapter 75, Article 2A, Appalachian State University (the "University") has developed an Identity Theft Prevention Program (the "Program") described below. This Program was developed with oversight and approval of the Board of Trustees of Appalachian State University (the "Board"). After consideration of the size and complexity of the Universitys operations and account systems, and the nature and scope of the Universitys activities, the Board determined that this Program was appropriate for the University, and approved it on September 24, 2010 (the "Effective Date"). The purpose of this Program is to detect, prevent and mitigate identity theft in connection with any covered account. This Program envisions the implementation of policies and procedures subject to the Chancellor's approval in order to achieve these goals.

Scope

2.1 All University personnel whose employment duties require or allow access to identifying information of other employees or students are responsible for implementing this Program.

Definitions

"Covered Account"

any account that constitutes a continuing financial relationship or is designed to permit multiple payments or transactions between the University and a person for a service, such as extension of credit, debit cards, Perkins Loans, Federal Family Education Loan Program (FFELP), institutional loans, accounts covered by the Health Insurance Portability and Accountability Act (HIPAA), deposit accounts, scholarship accounts, student accounts, and tuition payment plans.
any other account that the University offers or maintains for which there is a reasonably foreseeable risk to holders of the account or to the University from identity theft, such as use of consumer reports for employee background checks, credit applications and institutional debit card applications. This may include operations of utilities (e.g., New River Light & Power Company), clinical and research activities, and public service activities.

Identifying Information

means any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including, but not limited to:
  1. name
  2. address
  3. telephone number
  4. social security number
  5. date of birth
  6. government-issued driver's license or identification number
  7. alien registration number
  8. government passport number
  9. employer or taxpayer identification number
  10. individual identification number
  11. computer's Internet Protocol address
  12. bank or other financial account routing code

Identity Theft

means a fraud committed or attempted using the identifying information of another person without authority [16 CFR 603.2(a)].

Program Administrator

means the individual designated with primary responsibility for oversight of this Program.

Red Flag

means a pattern, practice, alert or specific activity that indicates the possible existence of identity theft.

Service Provider

means a person or entity that provides a service directly to the University.

Policy and Procedure Statements

Identification of Red Flags

4.1.1 In order to identify relevant red flags, the University considers the types of covered accounts it offers or maintains, the methods it provides to open its covered accounts, the methods it provides to access its covered accounts, and its previous experiences with identity theft. Red flags may be detected while implementing existing account opening and servicing procedures (example: individual identification, caller authentication, third party authorization, and address changes).

4.1.2 The University identifies the following as red flags in each of the listed categories:

  1. Notifications and warnings from consumer reporting agencies
    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
  2. Suspicious documents
    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 that appears to have been altered or forged.
  3. Suspicious personal identifying information
    1. Identifying information that is inconsistent with other information the individual provides (example: inconsistent birth dates);
    2. Identifying information that is inconsistent with other sources of information (example: an address not matching an address on a loan application);
    3. Identifying information that is the same as information shown on other applications that were found to be fraudulent;
    4. Identifying information that is consistent with fraudulent activity (examples: an invalid phone number or fictitious billing address);
    5. Social security number that is the same as one given by another individual;
    6. An address or phone number that is the same as that of another person;
    7. A person fails to provide complete personal identifying information on an application when reminded to do so; and
    8. A person's identifying information is not consistent with the information that is on file for the individual.
  4. Suspicious covered account activity
    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.
  5. Alerts from others
    1. Notice to the University from an identity theft victim, law enforcement officer or other person that the University has opened or is maintaining a fraudulent account for a person engaged in identity theft.

Detection of Red Flags

Student Enrollment

4.2.1.1 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

4.2.1.2 Identification card (example: review of driver's license or other government-issued photo identification).

New Customers or Clients

4.2.2.1 In order to detect any of the red flags identified above associated with service to a new customer or client, 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

4.2.2.2 Identification card (example: review of driver's license or other government-issued photo identification).

Existing Accounts

4.2.3.1 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.

Consumer ("Credit") Report Requests

In order to detect any of the red flags identified above in regard to 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 or background 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.

Response to Red Flags

4.3.1 Once potentially fraudulent activity is detected, an employee must act promptly to protect individuals and the University from damages and loss. At a minimum, the employee must gather all related documentation, write a description of the situation, and present this information to the program administrator.

4.3.2 The program administrator will complete additional investigation if necessary to determine whether the attempted transaction was fraudulent or authentic.

4.3.3 If a transaction is determined to be fraudulent, appropriate actions must be taken immediately. Actions may include (1) canceling the transaction; (2) notifying and cooperating with appropriate law enforcement personnel; (3) determining the extent of liability of the University; and (4) notifying the individual upon whom fraud has been attempted or whose identifying information has been subjected to a security breach.

Prevention and Mitigation of Identity Theft

In the event University personnel detect any identified red flags, such personnel shall take one or more of the following steps to prevent and mitigate identity theft, depending on their determination of the degree of risk posed by the red flag:

  1. Continue to monitor a covered account for evidence of identity theft;
  2. Contact the individual or applicant (for whom a credit or background 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 program administrator for determination of the appropriate step(s) to take;
  7. Notify appropriate law enforcement personnel;
  8. File or assist in filing a Suspicious Activity Report ("SAR") with the Financial Crimes Enforcement Network, United States Department of the Treasury; and/or
  9. Determine that no response is warranted under the particular circumstances.

Protect Identifying Information

In order to further prevent the likelihood of identity theft occurring with respect to covered accounts, the University will take the following steps to protect individual identifying information:

  1. Ensure that its website is secure or provide clear notice that the website is not secure;
  2. Ensure complete and secure destruction of paper documents and computer files containing individual account information when a decision has been made to no longer maintain such information;
  3. Ensure that office computers with access to covered account information are password protected;
  4. Ensure that laptops are password protected and encrypted;
  5. Avoid 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 identifying information that is necessary for University purposes.

Additional Identity Theft Prevention Measures

Hard Copy Distribution

Each employee and contractor performing work for the University will comply with the following procedures:

  1. File cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with identifying information will be locked when not in use.
  2. Storage rooms containing documents with identifying information and record retention areas will be locked at the end of each workday or when unsupervised.
  3. Desk workstations, work areas, printers and fax machines, and common shared work areas will be cleared of all documents containing identifying information when not in use.
  4. Whiteboards, dry-erase boards, writing tablets, and other writing surfaces in common shared work areas will be erased, removed, or shredded when not in use.
  5. When documents containing identifying information are discarded, they will be placed inside a locked shred bin or immediately shredded using a mechanical cross cut or Department of Defense-approved shredding device. Locked shred bins are labeled "Confidential paper shredding and recycling."

Program Administration

Oversight

The responsibility for developing, implementing and updating this Program lies with the program administrator designated by the Chancellor. The program administrator shall be responsible for ensuring appropriate training of University staff on the Program, for reviewing any staff reports regarding the detection of red flags and the steps for preventing and mitigating identity theft, determining which steps of prevention and mitigation should be taken in particular circumstances and considering periodic changes to the Program.

Staff Training

University employees responsible for implementing the Program shall be trained under the direction of the program administrator in the detection of red flags and the responsive steps to be taken when a red flag is detected.

Reports

Appropriate staff shall report to the program administrator at least annually on compliance 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.

Service Provider Arrangements

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 obligations in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft, including the following:

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

Program Updates

The program administrator shall review and update this Program at least annually to reflect changes in risks to individuals and the University from identity theft. In doing so, the program administrator shall consider the University's experiences with identity theft situations, changes in identity theft methods, changes in identity theft detection and prevention methods, and changes in the University's business arrangements with other entities.

Additional References

This Program incorporates by reference the following policies and procedures:

  1. Policy on the Use of Computers and Data Communication
  2. Computer Systems Security Policy
  3. University Remote Access Policy
  4. Trusted Access Policy
  5. Risk Assessment Policy
  6. Virtual Private Network (VPN) Policy
  7. Wireless Networking Policy
  8. Wireless to Trusted Network Policy
  9. Confidentiality Statement

Authority

16 CFR Part 681, implementing Section 114 of the Fair and Accurate Credit Transactions Act of 2003, Public Law 108-159 North Carolina General Statutes, Chapter 75, Article 2A

Contact Information

Effective Date

Revision Dates