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Identity Theft Prevention Operating Procedure 540.01

Identity Theft Prevention Operating Procedure 540.01
Johnson County Community College
Series: 500 Information Services
Section: Identity Theft Prevention

Cross-Reference: Identity Theft Prevention Policy 540.00
Data Classification and Security Operating Procedure 530.01

Applicability: This Operating Procedure applies to Johnson County Community College (“JCCC” or the “College”) employees using accounts covered by the Fair and Accurate Credit Transaction Act of 2003 (“FACTA”).

Purpose: The purpose of this Operating Procedure is to set forth the College’s Identity Theft Prevention Program (the “Program”) in accordance with the Identity Theft Policy 540.00.

Definitions:

“Identity Theft” means a fraud committed or attempted using the identifying information of another person without authority.

“Red Flag” is defined as a pattern, practice or specific activity that indicates the possible existence of Identity Theft

“Covered Account” means an account used mostly for personal, family or household purposes, and that involves multiple payments or transactions. Covered Accounts are also accounts for which there are foreseeable risks of Identity Theft. These include, but are not limited to, College deferred payment plans, loan accounts, Bursar and student accounts, and stored value cards

“Program Administrator”  means the individual tasked with primary responsibility for oversight of the Program, as designated in this Operating Procedure.

“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, student identification number, computer Internet Protocol address, or unique electronic identification number or routing code.

Procedures

JCCC developed this Program pursuant to the Federal Trade Commission’s (“FTC”) Red Flags Rule (“Red Flags Rule”), which implements Section 114 of FACTA. This Program was developed with oversight and approval from the College Board of Trustees.

I. Identity Theft Prevention Program

Pursuant to the Red Flags Rule, the College establishes this Program, which is tailored to the College’s size, complexity, and the nature of its operations. This Program contains procedures to:

  1. Identify relevant Red Flags for new and existing Covered Accounts and incorporate those Red Flags into the Program.
  2. Detect Red Flags that have been incorporated into the Program.
  3. Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity Theft.
  4. Ensure the Program is updated periodically to reflect changes in risks to College Covered Account users or to the safety and soundness of such users from Identity Theft.

II. Identification of Red Flags

In order to identify relevant Red Flags, the College considers the types of accounts that it offers and maintains, methods it provides to open its accounts, methods it provides to access its accounts, and its previous experiences with Identity Theft. The College identifies the following Red Flags in each of the listed categories:

A. Red Flags: 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 Identifying Information
  4. Application for service that appears to have been altered or forged.

B. Red Flags: Suspicious Personal Identifying Information


  1. Identifying Information presented that is inconsistent with other information provided (example: inconsistent birth dates).
  2. Identifying Information presented that is inconsistent with other sources of information (for instance, an address not matching an address on a loan application).
  3. Identifying Information presented that is the same as information shown on other applications that were found to be fraudulent
  4. Identifying Information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address).
  5. Social security number presented that is the same as one given to the College by another person.
  6. An address or phone number presented that is the same as that given to the College by another person.
  7. A person fails to provide complete Identifying Information on an application when reminded by the College to do so.
  8. Identifying Information presented is not consistent with the information that is already on file with the College for the person.

C. Red Flags: Suspicious or Unusual Use of a College Covered Account

  1. Change of address for a College Covered Account followed by a request to change the person’s name on file with the College.
  2. Payments stop on an otherwise consistently up-to-date College Covered Account
  3. College Covered Account used in a way that is not consistent with prior use.
  4. Mail sent by the College to a student or employee is repeatedly returned as undeliverable.
  5. Notice to the College that a student or employee is not receiving mail sent by the College.
  6. Notice to the College that a College Covered Account has unauthorized activity
  7. Breach in the College's computer system security.
  8. Unauthorized access to or use of College Covered Account information.

D. Red Flags: Alerts from Others

Notice to the College from a student, employee, Identity Theft victim, law enforcement officer, or other person that the College has opened or is maintaining a fraudulent account for a person engaged in Identity Theft.

III. Detecting Red Flags

A. Detection - Student Enrollment

In order to detect any of the Red Flags identified above associated with the enrollment of a student, College personnel will take the following steps to obtain and verify the identity of the person opening the account

  1. Require Identifying Information, such as name, date of birth, academic records, home address or other identification, on College application.
  2. Verify the student’s identity at time of issuance of student identification card by reviewing the student’s driver’s license or other government-issued photo identification.

B. Detection - Existing Accounts

In order to detect any of the Red Flags identified above for an existing Covered Account, College personnel will take the following steps to monitor transactions on an account:

  1. Verify the identification of students or employees if they request information from the College about Sensitive or Restricted Data, as defined in the Data Classification and Security Operating Procedure 530.01
  2. Verify the validity of requests to change billing addresses by mail or email and provide students a reasonable means of promptly reporting incorrect billing address changes.
  3. Verify changes in banking information given for billing and payment purposes.

C. Detection - Consumer Report Requests

In order to detect any of the Red Flags identified above for an employment or volunteer position for which a background report or credit check is sought or for financial aid purposes, College personnel will take the following steps to assist in identifying discrepancies:

  1. In the event that notice of a social security discrepancy is received, verify that the consumer report pertains to the applicant for whom the requested report was made.
  2. Verify the validity of the applicant’s social security number.

IV. Preventing and Mitigating Identity Theft

In the event College personnel detect any Red Flags as outlined in this Program, such personnel will take one or more of the following steps, depending on the degree of risk posed by the Red Flag:

A. Prevent and Mitigate

  1. Continue to monitor accounts for evidence of Identity Theft.
  2. Contact the applicant for which a consumer report was run.
  3. Change any passwords or other security devices that permit access to the College Covered Account.
  4. Provide a student or employee with a new identification number.
  5. Notify the Program Administrator.
  6. Notify law enforcement.
  7. Determine that no response is warranted under the specific circumstances.

B. Protect Identifying Information

In order to further prevent the likelihood of Identity Theft occurring with respect to College Covered Accounts, the College will take the following steps with respect to its internal procedures to protect 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 College Covered Account Identifying Information when a decision has been made to no longer maintain such Identifying Information.
  3. Ensure that office computers with access to College Covered Account Identifying Information are password protected.
  4. Limit the use of social security numbers.
  5. Ensure computer virus protection is up to date.
  6. Require and keep only the kinds of Identifying Information that are necessary for College purposes.

V. Program Administration

A. Oversight

Responsibility for developing, implementing, and updating this Program resides with the JCCC Identity Theft Committee (“Committee”). The Committee is headed by a Program Administrator appointed by the President or designee. The Program Administrator will be responsible for establishing membership on the Committee, ensuring appropriate training of College employees on the Program, reviewing any employee 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.

B. Employee Training and Reports

College employees responsible for implementing the Program shall be trained either by or 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. College employees shall be trained, as necessary, to effectively implement the Program. College employees are expected to notify the Program Administrator once they become aware of an incident of Identity Theft or of the College’s failure to comply with this Program. At least annually, Committee members responsible for development, implementation and administration of the Program shall report to the Program Administrator on compliance with this Program. The reports should address such issues as effectiveness of the policies and procedures in addressing the risk of Identity Theft in connection with the opening and maintenance of Covered Accounts, service provider arrangements, significant incidents involving Identity Theft and management’s response, and recommendations for changes to the Program.

C. Service Provider Arrangements

In the event the College engages a service provider to perform an activity in connection with one or more College Covered Accounts, the College will take the following steps to ensure the service provider performs its activities in accordance with this Program.

  1. Require, by contract, that service providers have such policies and procedures in place that comply with this Program, FACTA and the Red Flags Rule.
  2. Require, by contract, that service providers review the College's Program and report any Red Flags to the Program Administrator or the College personnel with primary oversight of the service provider relationship.

D. Non-Disclosure of Specific Practices

For the effectiveness of this Program, knowledge about specific Red Flag identification, detection, mitigation, and prevention practices may need to be limited to the Committee and to those personnel who need to know them. Any documents that may have been produced or are produced in order to develop or implement this Program that list or describe such specific practices and the information those documents contain are considered Restricted Data, as defined in the Data Classification and Security Operating Procedure 530.01, and should not be shared with other College personnel or the public. The Program Administrator shall inform the Committee and those personnel who need to know the information in those documents or specific practices which should be maintained in a confidential manner.

E. Program Updates

The Committee will periodically review and update this Program to reflect changes in risks to College Covered Accounts and to increase the soundness of this Program to best protect the College from Identity Theft. In doing so, the Committee will consider the College's experiences with Identity Theft situations; changes in Identity Theft methods, detection and prevention; and changes in the College's business arrangements with other entities. After considering these factors, the Program Administrator will determine whether changes to the Program, including the listing of Red Flags, are warranted. If warranted, the Committee will update the Program.

Signature on File in Policy Office
President

Date of Adoption: 11/20/2009
Revised: 11/21/2019 (renumbered from 424.02), 12/15/2022