The purpose of this policy is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity theft in connection with the opening of a covered account or an existing covered account and to provide for continued administration of the Program. Further, the efforts and resources committed must be appropriate to the size and complexity of the organization and the nature and scope of its activities. The Program shall include reasonable policies and procedures to:
- Identify relevant red flags to ensure the detection of possible risk of identity theft to customers and incorporate those red flags into the Program;
- Detect red flags that have been incorporated into the Program;
- Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
- Ensure the Program is updated periodically to reflect changes in risks to customers and to the safety and soundness of the creditor from identity theft
Administration of the Program is with the Vice President of Finance and Administration in development, implementation and oversight. This includes ongoing staff training and oversight of service provider arrangements to ensure compliance.
Pacific University developed this identity Theft Prevention Program (“Program”) pursuant to the Federal Trade Commission’s Red Flags Rule, which implements Section 114 of the Fair and Accurate Credit Transactions Act (FACT ACT) of 2003. This program was received and reviewed by the Executive Committee of the Board of Trustees on April 13th, 2009. The program was then sent to the Finance Committee to review on May 22, 2009. The Finance Committee forwarded the policy to the Audit Committee for approval. After consideration of the size of the University’s operations and accounting systems, and the nature and scope of the University’s activities, the Audit Committee determined that this Program was appropriate for Pacific University, and therefore approved this Program on June 10, 2009.
Policy requires PUNet ID to review.