Identity Theft Prevention Plan and Tailgating: Difference between pages

From Appalachian State University Policy Manual
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Policy 105.3
Policy 106.3
== Introduction ==
== 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 ==
== 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.
2.1 This policy applies to all faculty, staff, students, as well as visitors to the campus or non-campus property.


== Definitions  ==
== 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.
=== Tailgating ===
 
:Tailgating is defined as parking in a designated location or area and/or setting up non- permanent facilities (such as tents and tables) to consume food and beverages prior to an officially sanctioned University event to which the public is invited and the event has been approved for tailgating. If the Chancellor or his designee pre-approves the consumption of alcohol for a specific tailgating event, only malt beverages and unfortified wine may be consumed by individuals twenty-one (21) years of age or older.
=== 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:
 
#name
#address
#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
 
=== 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  ==
== Policy and Procedure Statements  ==


=== Identification of Red Flags ===
=== Conduct ===
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).
4.1.1 Individuals attending events at Appalachian State University are expected to conduct themselves in a manner respectful of the nature and character of the university. Persons acting in a disruptive, disrespectful or disorderly manner may be asked to leave the premises or be subject to citation. Students may also be charged with a violation of the Code of Student Conduct.


4.1.2 The University identifies the following as red flags in each of the listed categories:
4.1.2 '''APPALACHIAN STATE UNIVERSITY DOES NOT SANCTION THE CONSUMPTION OR POSSESSION OF ALCOHOLIC BEVERAGES BY UNDERAGE PERSONS; NOR DOES IT SANCTION THE VIOLATION OF FEDERAL, STATE OR LOCAL LAW.'''


#Notifications and warnings from consumer reporting agencies
=== Tailgating Areas/Times ===
##Report of fraud accompanying a credit report;
4.2.1 Tailgating with food and non-alcoholic beverages is permitted on all areas of campus.
##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.


=== Detection of Red Flags ===
4.2.2 Possession and consumption of alcoholic beverages while tailgating will be permitted in the following areas, or those parking lots adjacent to the facilities listed below, unless otherwise stipulated by the University Administration:


==== Student Enrollment ====
{|
|Broyhill Music Building Lot                       
|Chemistry and Physics (CAP) Lot
|-
|Champions Lot                                   
|Duck Pond Field
|-
|Durham Park
|East Stands Lot
|-
|Edwin Duncan Hall Lot                           
|Farthing Auditorium Lot
|-
|Greenwood Lot                                     
|Holmes Center Lot
|-
|John Thomas Hall Lot                             
|Justice/Coltrane Halls Lots
|-
|Katharine Harper Hall Lot
|Legends Lot                       
|-
|Raley Lot
|Rivers Street Parking Deck                       
|-
|South Lot
|Stadium Lot
|-                                     
|Student Recreation Center Lot                     
|University Drive Parking Spaces
|-
|New Parking Deck next to the Carol Grotnes Belk Library and Information Commons
|}


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:
4.2.3 '''THE ABOVE DESIGNATED AREAS ARE THE ONLY LOCATIONS APPROVED FOR TAILGATING WITH ALCOHOL. Consumption of alcohol outside designated areas and/or time periods constitutes a violation of Appalachian State University tailgating policy. Violators are subject to prosecution under the
Appalachian State University Code of Student Conduct, the laws of The Town of Boone, and/or the laws of the State of North Carolina.'''


#Require certain identifying information such as name, date of birth, academic records, home address or other identification; and
4.2.3.1 Alcohol consumption will not be permitted in any area during or after the game.
#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 ====
4.2.3.2 Tailgating is limited to directly behind your parked vehicle. '''Roadways cannot be blocked for any reason and more than one parking spot cannot be used.'''


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:
4.2.3.3 Motor homes will not be allowed to park in campus parking lots the night before a game.


#Require certain identifying information such as name, date of birth, academic records, home address or other identification; and
4.2.3.4 <u>Tailgating sites will not open prior to 9:00 A.M. before the official beginning of the event.</u>
#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).
4.2.3.5 Tailgating will not be permitted during the event.


==== Existing Accounts ====
=== Consumption of Alcohol ===


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:
4.3.1 Consistent with North Carolina State Law, <u>only malt beverages and unfortified wine may be possessed or consumed. Spirituous liquor (including mixed drinks) is NOT permitted.</u>


#Verify the identification of individuals if they request information (in person, via telephone, via facsimile, via email);
4.3.2 Kegs and other common containers are not allowed at any time.
#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.


==== Consumer ("Credit") Report Requests ====
4.3.3 Glass containers are not allowed.


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:
4.3.4 Drinking games, including, but not limited to, beer pong, and the use of devices intended to accelerate the consumption of alcohol, including, but not limited to, funnels or beer bongs, are prohibited.


#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
4.3.5 Any participant who consumes alcoholic beverages at such events <u>must be able to produce a valid driver’s license or other photo ID that reflects the person’s age</u> upon request.
#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 ===
4.3.6 Consumption of alcoholic beverages is prohibited on any other part of the campus or on public streets that run through or are adjacent to the campus.


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.
4.3.7 Consumption of alcoholic beverages may begin no more than 3 ½ hours before the starting time of the event. Consumption of alcoholic beverages '''after''' commencement of the event is '''prohibited'''. For more information see [http://policy.appstate.edu/Possession_and_Use_of_Alcoholic_Beverages Possession and Use of Alcoholic Beverages]


4.3.2 The program administrator will complete additional investigation if necessary to determine whether the attempted transaction was fraudulent or authentic.
=== Consumption and Preparation of Food ===


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.
4.4.1 No food may be sold without proper University permit (either Food Services and/or Athletics).


=== Prevention and Mitigation of Identity Theft ===
4.4.2 Propane and charcoal grills are the only permissible sources of heat for cooking. Burned coals and/or residue from cooking may not be permitted to make contact with the paved surface of the parking lot. Hot coals must be completely extinguished with water prior to leaving the tailgating site.


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:
4.4.3 Open flame fires, including fire pits, are prohibited.


#Continue to monitor a covered account for evidence of identity theft; 
=== Trash ===
#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.


==== Protect Identifying Information ====
4.5.1 All groups and individuals participating in tailgating are responsible for proper disposal of their trash and other debris such as charcoal.
Recycling is strongly encouraged.


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:
4.5.2 Trash containers will be provided throughout campus.


#Ensure that its website is secure or provide clear notice that the website is not secure;
=== Solicitation ===
#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.


=== Additional Identity Theft Prevention Measures ===
4.6.1 No sales activities are allowed on the Appalachian State University campus, including any/all tailgating areas, without permission from the appropriate University office, i.e. Athletics and/or Center for Student Involvement and Leadership.
==== Hard Copy Distribution ====
[http://policy.appstate.edu/Facility_Use Facility Use Policy].
Each employee and contractor performing work for the University will comply with the following procedures:


#File cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with identifying information will be locked when not in use.
4.6.2 Only Appalachian State University Athletics or their designated representatives will be allowed to sell merchandise at athletics events.
#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."


=== Program Administration ===
=== Structures ===
==== 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 ====
4.7.1 No permanent or semi-permanent structures may be constructed or placed for any activity on University grounds except by authority of the Vice Chancellor for Business Affairs or the Vice Chancellor for Student Development(Facility Use Policy, Section 5-Use of University Grounds and Exterior Facilities, Resource Manual).
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 ====
=== Smoking Policy ===
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 ====
4.8.1 Smoking is not allowed inside Kidd Brewer Stadium or within 50 ft. of any university facility.
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:


#Require, by signed contract, that service providers have such policies and procedures in place; and
4.8.2 If smoking in a designated area, smoking residue must be placed in appropriate receptacles. (Smoking Policy, Resource Manual)
#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 ==
== Additional References ==
This Program incorporates by reference the following policies and procedures:
#[http://policy.appstate.edu/Use_of_Computers_and_Data_Communications Policy on the Use of Computers and Data Communication]
#[http://www.nss.appstate.edu/standards/open-servers-vlan-policy Computer Systems Security Policy]
#[http://policy.appstate.edu/Remote_Access_Policy Remote Access Policy]
#[http://policy.appstate.edu/Trusted_Access_Policy Trusted Access Policy]
#[http://policy.appstate.edu/Network_Risk_Assessment_Policy Network Risk Assessment Policy]
#[http://policy.appstate.edu/Virtual_Private_Network_(VPN)_Policy Virtual Private Network (VPN) Policy]
#[http://policy.appstate.edu/Wireless_Networking_Policy_and_Process Wireless Networking Policy]
#[http://policy.appstate.edu/Wireless_Networking_Policy_and_Process Wireless to Trusted Network Policy]
#[http://policy.appstate.edu/Statement_of_Confidentiality Statement of Confidentiality]


== Authority ==
== Authority ==


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


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




== Original Effective Date ==
== Effective Date ==


== Revision Dates ==
== Revision Dates ==
:November 5, 2021 - previously policy 105.5
[[Category:Contents]]
[[Category:Governance and Administration]]
[[Category:Records]]

Revision as of 19:59, 15 March 2012

Policy 106.3

Introduction

Scope

2.1 This policy applies to all faculty, staff, students, as well as visitors to the campus or non-campus property.

Definitions

Tailgating

Tailgating is defined as parking in a designated location or area and/or setting up non- permanent facilities (such as tents and tables) to consume food and beverages prior to an officially sanctioned University event to which the public is invited and the event has been approved for tailgating. If the Chancellor or his designee pre-approves the consumption of alcohol for a specific tailgating event, only malt beverages and unfortified wine may be consumed by individuals twenty-one (21) years of age or older.

Policy and Procedure Statements

Conduct

4.1.1 Individuals attending events at Appalachian State University are expected to conduct themselves in a manner respectful of the nature and character of the university. Persons acting in a disruptive, disrespectful or disorderly manner may be asked to leave the premises or be subject to citation. Students may also be charged with a violation of the Code of Student Conduct.

4.1.2 APPALACHIAN STATE UNIVERSITY DOES NOT SANCTION THE CONSUMPTION OR POSSESSION OF ALCOHOLIC BEVERAGES BY UNDERAGE PERSONS; NOR DOES IT SANCTION THE VIOLATION OF FEDERAL, STATE OR LOCAL LAW.

Tailgating Areas/Times

4.2.1 Tailgating with food and non-alcoholic beverages is permitted on all areas of campus.

4.2.2 Possession and consumption of alcoholic beverages while tailgating will be permitted in the following areas, or those parking lots adjacent to the facilities listed below, unless otherwise stipulated by the University Administration:

Broyhill Music Building Lot Chemistry and Physics (CAP) Lot
Champions Lot Duck Pond Field
Durham Park East Stands Lot
Edwin Duncan Hall Lot Farthing Auditorium Lot
Greenwood Lot Holmes Center Lot
John Thomas Hall Lot Justice/Coltrane Halls Lots
Katharine Harper Hall Lot Legends Lot
Raley Lot Rivers Street Parking Deck
South Lot Stadium Lot
Student Recreation Center Lot University Drive Parking Spaces
New Parking Deck next to the Carol Grotnes Belk Library and Information Commons

4.2.3 THE ABOVE DESIGNATED AREAS ARE THE ONLY LOCATIONS APPROVED FOR TAILGATING WITH ALCOHOL. Consumption of alcohol outside designated areas and/or time periods constitutes a violation of Appalachian State University tailgating policy. Violators are subject to prosecution under the Appalachian State University Code of Student Conduct, the laws of The Town of Boone, and/or the laws of the State of North Carolina.

4.2.3.1 Alcohol consumption will not be permitted in any area during or after the game.

4.2.3.2 Tailgating is limited to directly behind your parked vehicle. Roadways cannot be blocked for any reason and more than one parking spot cannot be used.

4.2.3.3 Motor homes will not be allowed to park in campus parking lots the night before a game.

4.2.3.4 Tailgating sites will not open prior to 9:00 A.M. before the official beginning of the event.

4.2.3.5 Tailgating will not be permitted during the event.

Consumption of Alcohol

4.3.1 Consistent with North Carolina State Law, only malt beverages and unfortified wine may be possessed or consumed. Spirituous liquor (including mixed drinks) is NOT permitted.

4.3.2 Kegs and other common containers are not allowed at any time.

4.3.3 Glass containers are not allowed.

4.3.4 Drinking games, including, but not limited to, beer pong, and the use of devices intended to accelerate the consumption of alcohol, including, but not limited to, funnels or beer bongs, are prohibited.

4.3.5 Any participant who consumes alcoholic beverages at such events must be able to produce a valid driver’s license or other photo ID that reflects the person’s age upon request.

4.3.6 Consumption of alcoholic beverages is prohibited on any other part of the campus or on public streets that run through or are adjacent to the campus.

4.3.7 Consumption of alcoholic beverages may begin no more than 3 ½ hours before the starting time of the event. Consumption of alcoholic beverages after commencement of the event is prohibited. For more information see Possession and Use of Alcoholic Beverages

Consumption and Preparation of Food

4.4.1 No food may be sold without proper University permit (either Food Services and/or Athletics).

4.4.2 Propane and charcoal grills are the only permissible sources of heat for cooking. Burned coals and/or residue from cooking may not be permitted to make contact with the paved surface of the parking lot. Hot coals must be completely extinguished with water prior to leaving the tailgating site.

4.4.3 Open flame fires, including fire pits, are prohibited.

Trash

4.5.1 All groups and individuals participating in tailgating are responsible for proper disposal of their trash and other debris such as charcoal. Recycling is strongly encouraged.

4.5.2 Trash containers will be provided throughout campus.

Solicitation

4.6.1 No sales activities are allowed on the Appalachian State University campus, including any/all tailgating areas, without permission from the appropriate University office, i.e. Athletics and/or Center for Student Involvement and Leadership. Facility Use Policy.

4.6.2 Only Appalachian State University Athletics or their designated representatives will be allowed to sell merchandise at athletics events.

Structures

4.7.1 No permanent or semi-permanent structures may be constructed or placed for any activity on University grounds except by authority of the Vice Chancellor for Business Affairs or the Vice Chancellor for Student Development(Facility Use Policy, Section 5-Use of University Grounds and Exterior Facilities, Resource Manual).

Smoking Policy

4.8.1 Smoking is not allowed inside Kidd Brewer Stadium or within 50 ft. of any university facility.

4.8.2 If smoking in a designated area, smoking residue must be placed in appropriate receptacles. (Smoking Policy, Resource Manual)

Additional References

Authority

Contact Information

Effective Date

Revision Dates

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