Sec. 2-230. Oversight of the program.
(a) The oversight of this program shall be undertaken by the Town Manager and clerk-treasurer. Such oversight shall include:
(1) Staffing. Assignment of specific responsibility for implementation of the program to appropriate utility staff—the Town Manager and clerk-treasurer shall be responsible for the day to day administration of this program and shall report directly to the Town Council in connection with any matters relating to this program;
(2) Review of reports. Review of reports prepared by staff regarding compliance—such reports to be presented by the Town Manager and clerk-treasurer to the Town Council; and
(3) Approval of program changes. Approval of material changes to this program as necessary to address changing risks of identity theft.
(b) Reports shall be prepared as follows:
(1) Annual report. The Town Manager and clerk-treasurer, responsible for the day to day development, implementation and administration of the program, shall report to the Town Council at least annually on compliance by the Town and utilities with the program.
(2) Content of report. The report shall address material matters related to this program and evaluate issues such as:
a. Effectiveness of the policies and procedures in addressing the risk of identity theft in connection with the opening of covered accounts and with respect to existing covered accounts;
b. Service provider agreements;
(c) Significant incidents involving identity theft and management's response; and
(d) Recommendations for material changes to this program.