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The Town Council shall update this program periodically to reflect changes in risks to customers of the utilities or to the safety and soundness of the utilities and its customers from identity theft based on factors such as:

(1) Experience. The experiences of the utilities and town with identity theft;

(2) Changes in methods. Changes in methods of identity theft and in methods to detect, prevent and mitigate identity theft;

(3) Changes in accounts. Changes in the types of accounts that the Town and utilities offer or maintain;

(4) Changes in business. Changes in the business arrangements of the Town and utilities, including acquisitions, alliances and service provider arrangements.

(Ord. No. 1489, § 1(Exh. A), 4-23-09)