Red Flags Rule
I. PROGRAM ADOPTION
Denver Seminary (“Seminary”) 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 of 2003. This Program was developed with oversight and approval of the Denver Seminary Board of Trustees and in consideration of the size and complexity of the Seminary’s operations and account systems and the nature and scope of the Seminary’s activities.
II. RED FLAGS RULE DEFINITIONS
- “Identity Theft” is a “fraud committed or attempted using the identifying information of another person without authority.”
- A “Red Flag” is a “pattern, practice, or specific activity that indicates the possible existence of Identity Theft.”
- A “Covered Account” includes all student accounts or payment plans that are administered by the Seminary.
- “Program Administrator” is the individual designated with primary responsibility for oversight of the program. (See Section VII below.)
- “Identifying information” is “any name or number that may be used, alone or in conjunction with any other information, to identify a specific person,” including: 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’s Internet Protocol address, or routing code.
III. REQUIREMENTS OF THE RED FLAGS RULE
Under the Red Flags Rule, the Seminary is required to establish an “Identity Theft Prevention Program” tailored to its size, complexity and the nature of its operation. Each program must contain reasonable policies and 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; and
4. Ensure the Program is updated periodically to reflect changes in risks to students or to the safety and soundness of the student from Identity Theft.
(Note: There is an additional requirement to address the treatment and reporting of address discrepancies in conjunction with reports received from a consumer reporting agency. However, in that the Seminary does not receive such reports, it is not necessary to include this requirement in the Program at this time.)
IV. IDENTIFICATION OF RED FLAGS
In order to identify relevant Red Flags, the Seminary 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 Seminary identifies the following Red Flags in each of the listed categories:
A. 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 student information; or
4. Application or request for services that appears to have been altered or forged.
B. Suspicious Personal Identifying Information
1. Identifying information presented that is inconsistent with other information the student provides (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 financial aid 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 by another student;
6. An address or phone number presented that is the same as that of another person;
7. A person failing to provide complete personal identifying information on an application when reminded to do so; or
8. A person’s identifying information not consistent with the information that is on file for the student.
C. Suspicious Covered Account Activity or Unusual Use of Account
1. Change of address for an account followed by a request to change the student’s name;
2. Payments stop on an otherwise consistently up-to-date account;
3. Account used in a way that is not consistent with prior use;
4. Mail sent to the student that is repeatedly returned as undeliverable;
5. Notice to the Seminary that a student is not receiving mail sent by the Seminary;
6. Notice to the Seminary that an account has unauthorized activity;
7. Breach in the Seminary’s computer system security; or
8. Unauthorized access to or use of student account information.
D. Alerts from Others
1. Notice to the Seminary from a student, Identity Theft victim, law enforcement or other person that the Seminary has opened or is maintaining a fraudulent account for a person engaged in Identity Theft.
V. DETECTING RED FLAGS
A. When Establishing New Accounts
In order to detect any of the Red Flags identified above associated with the enrollment of a student, Seminary personnel will take the following steps to obtain and verify the identity of the person opening the account:
1. Require certain identifying information such as name, date of birth, academic records, home address or other identification;
2. Record social security numbers directly into the Seminary’s computer system and otherwise neither record nor maintain them;
3. Assign an account number and personal identification number (PIN) which shall be unique to that account; and
4. Re-verify the student’s identity at the time of issuance of student identification card (review of driver’s license or other government-issued photo identification).
B. When Maintaining Existing Accounts
In order to detect any of the Red Flags identified above for an existing Covered Account, Seminary personnel will take the following steps to monitor transactions on an account:
1. Verify the identification of students if they request information (in person, via telephone, via facsimile or via email);
2. Verify the validity of requests to change billing addresses by mail or email and provide the student a reasonable means of promptly reporting incorrect billing address changes; and
3. Verify changes in banking information given for billing and payment purposes.
VI. PREVENTING AND MITIGATING IDENTITY THEFT
A. Prevention
In order to prevent the likelihood of Identity Theft occurring with respect to Covered Accounts, the Seminary will take the following steps with respect to its internal operating procedures to protect student identifying information:
1. Maintain security of the Seminary website;
2. Protect access to all Seminary computers with secure passwords;
3. Update computer virus protection on a regular basis;
4. Ensure that access to all Covered Accounts are password protected and limited to authorized personnel;
5. Require that all passwords be changed on a regular basis;
6. Report any unauthorized access to or breach of a Covered Account immediately to the Program Administrator;
7. Avoid the use of social security numbers in any accessible document;
8. Mask social security numbers to the extent possible in all Seminary data bases;
9. Accept credit card payments through the Internet via processing by a third party service provider, such provider certifying that it has an adequate identity theft prevention program in place;
10. Accept credit card payments over the phone by directly entering the information into the terminal and securely destroying any written evidence of the information;
11. Include only the last four digits of a credit card, debit card or bank account number in any issued receipt;
12. Ensure complete and secure destruction of paper documents and computer files containing student account or financial information in accordance with the Seminary’s Record Retention Policy; and
13. Require and keep only the kinds of student information absolutely necessary for Seminary business purposes.
B. Mitigation
In the event Seminary personnel detect any identified Red Flags, such personnel shall take one or more of the following steps, depending on the degree of risk posed by the Red Flag:
1. Notify the Program Administrator for determination of the appropriate step(s) to take;
2. Contact the student or applicant;
3. Continue to monitor a Covered Account for evidence of Identity Theft;
4. Change any passwords or other security devices that permit access to Covered Accounts;
5. Provide the student with a new student identification number;
6. Opt not to open a new Covered Account;
7. File or assist in filing a Suspicious Activities Report (“SAR”);
8. Notify law enforcement; or
9. Determine that no response is warranted under the particular circumstances.
VII. PROGRAM ADMINISTRATION
A. Oversight
Responsibility for developing, implementing and updating this Program lies with an Identity Theft Committee (“Committee”) for the Seminary. The Committee is headed by a Program Administrator who shall be the President of the Seminary or his or her appointee. Two or more other individuals appointed by the Program Administrator comprise the remainder of the committee membership. The Program Administrator will be responsible for ensuring appropriate training of Seminary staff on the Program, for reviewing any staff 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. Staff Training and Responsibilities
Seminary staff 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. Seminary staff shall be trained, as necessary, to effectively implement the Program. Seminary employees are expected to notify the Program Administrator once they become aware of an incident of Identity Theft or of the Seminary’s failure to comply with this Program.
Specific staff responsibilities in relation to the Seminary’s Red Flags Rule Program shall include, but not be limited to:
1. Admissions
a. Establish new accounts in accordance with the Program
b. Change applicant information in accordance with the Program
c. Verify identifying documents for new students
2. Enrollment Management
a. Change student information in accordance with the Program
b. Issue Seminary ID only upon identity verification
3. Financial Aid
a. Verify documents submitted for financial aid qualification
b. Respond to requests for information concerning financial aid in accordance with the Program
4. Office of the Registrar
a. Change addresses and other student information in accordance with the Program
b. Respond to requests for student documents, such as transcripts, in accordance with the Program
c. Verify international student documentation
5. Business Office:
a. Initiate and regularly monitor the Red Flags Rule Program
b. Certify Red Flags Rule Program compliance by any third party providers
6. Financial Services
a. Respond to requests for information concerning student accounts in accordance with the Program
b. Issue 1098-T documents accounts in accordance with the Program
c. Accept credit card payments only in accordance with the Program
7. Human Resources
a. Educate and train employees concerning the Red Flags Rule Program
b. Change addresses and other employee information in accordance with the Program
c. Verify identifying documents for new employee
d. Complete background checks on new employees
8. Payroll
a. Respond to requests for payroll information in accordance with the Program
b. Issue payroll documents in accordance with the Program
9. Library
a. Change student information in accordance with the Program
b. Issue Seminary ID only upon identity verification
10. Advancement
a. Establish donor accounts in accordance with the Program
b. Change donor information in accordance with the Program
11. Technology Services
a. Assess technology risks and weaknesses
b. Maintain all computer and data base access passwords
c. Designate an IT staff member to be an Identity Theft technology specialist
C. Annual Reports
At least annually or as otherwise requested by the Program Administrator, Seminary staff responsible for development, implementation, and administration of the Program shall report to the Program Administrator on compliance with this Program. The report 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 along with management’s response, and recommendations for changes to the Program.
D. Service Provider Arrangements
In the event the Seminary engages a service provider to perform an activity in connection with one or more Covered Accounts, the Seminary will take the following steps to ensure the service provider performs its activity in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of Identity Theft.
1. Require, by contract, that service providers have such policies and procedures in place; and
2. Require, by contract, that service providers review the Seminary’s Program and report any Red Flags to the Program Administrator or the Seminary employee with primary oversight of the service provider relationship.
E. Program Updates
The Committee will periodically review and update this Program to reflect changes in risks to students and the soundness of the Seminary from Identity Theft. In doing so, the Committee will consider the Seminary’s experiences with Identity Theft situations, changes in Identity Theft methods, changes in Identity Theft detection and prevention methods, and changes in the Seminary’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.
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Issued By: |
Administrative Committee |
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Approved By: |
Board of Trustees |
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Approval Date: |
April 2009 |
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Effective Date |
May 1, 2009 |
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Annual Revision Dates: |
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Required Review (Year): |
2010 |
