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This program provides for appropriate responses to detected red flags to prevent and mitigate identity theft. The response shall be commensurate with the degree of risk posed. Appropriate responses include:

(1) Monitoring. Monitoring a covered account for evidence of identity theft;

(2) Customer contact. Contacting the customer (contact may be made by e-mail, certified mail or telephone to the affected customer);

(3) Change passcodes. Changing any passwords, security codes or other security devices that permit access to a covered account;

(4) New account number. Reopening a covered account with a new account number;

(5) Not open. Not opening a new covered account;

(6) Close. Closing an existing covered account;

(7) Notify law enforcement. Notifying the Town's Police Department and any other necessary law enforcement personnel; or

(8) Not respond. Determining that no response is warranted under the particular circumstances.

Any town or utilities staff employee who becomes aware of a suspected or actual fraudulent use of a customer or potential customer's identity must first and immediately notify the Town Manager and clerk-treasurer. The Town Manager and clerk-treasurer will then determine the appropriate response in accordance with one or more of the options above.

In the event notification to a customer is necessary, such notification shall include relevant information related to the incident including (i) the type of identifying information involved; (ii) the telephone number that the person can call for further information and assistance; (iii) local law enforcement contact information; and (iv) Federal Trade Commission contact information (877-438-4338 or www.consumer.gov/idtheft).

(Ord. No. 1489, § 1(Exh. A), 4-23-09)