Saginaw Valley State University (SVSU), in response to a growing problem of identity theft, endeavors to safeguard personal and private information of all of its constituents, including faculty, staff, students, vendors, volunteers and donors. Additionally, the University recognizes that some activities of the University are subject to the provisions of the Fair and Accurate Credit Transactions Act ("FACTA") and the "Red Flag" rules. Therefore, the Board of Control of SVSU adopts the following initial Identity Theft Prevention policy designed to detect, prevent and mitigate identity theft in connection with conducting University business.
The University has adopted this initial Identity Theft Prevention Policy in compliance with the "Red Flag" rules issued by the Federal Trade Commission pursuant to FACTA. After consideration of the size and complexity of the University's operations and account systems, and the nature and scope of the University's activities, management and the Board of Control have determined that this policy is appropriate for the University.
Pursuant to the Red Flag regulations at 16 C. F. R. § 681.2, the following definitions shall apply to this policy:
1. Any account the University offers or maintains primarily for personal, family or household purposes, that involves multiple payments or transactions.
2. Any other account the University offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the University from identity theft, including financial, operational, compliance, reputation, or litigation risks.
"Credit:" The right granted by a creditor to a debtor to defer payment of debt or to incur debt and defer its payment or to purchase property or services and defer payment therefore.
“Creditor:” An entity that regularly extends, renews or continues credit.
“Customer:” Any person with a covered account with a creditor.
"Identifying information:" 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, unique electronic identification number, or computer's Internet Protocol address or routing code.
"Identity theft:" A fraud committed using the identifying information of another person without authority.
"Red Flag:" A pattern, practice or specific activity that indicates the possible existence of identity theft.
The University is required to establish an Identity Theft Prevention Program (the "Program") to detect, prevent, and mitigate identity theft. The Program shall include reasonable policies and procedures to:
1. Identify relevant Red Flags for covered accounts it offers or maintains and incorporate those Red Flags into the Program.
2. Detect and record 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 identity theft risks to customers and to the safety and soundness of the University in its role as creditor.
The Program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.
The Board of Control has designated the Executive Vice President for Administration and Business Affairs, or his designee, to serve as Program Administrator. The Program Administrator shall exercise appropriate and effective oversight over the Program and shall report to the President's Staff on the Program.
The Program Administrator, with the assistance of the Identity Theft Prevention Program Committee, is responsible for developing, implementing and updating the Program throughout the University system. The Program Committee will be responsible for ensuring appropriate training of University staff on the Program, for reviewing any staff reports regarding the detection of Red Flags and the steps for identifying, 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.
The Program will be periodically reviewed and updated to reflect changes in identity theft risks and technological changes. The Program Administrator will consider the University's experiences with identity theft, changes in identity theft methods, changes in identity theft detection, mitigation and prevention methods, changes in types of accounts the University maintains, changes in the University's business arrangements with other entities, and any changes in legal requirements in the area of identity theft. After considering these factors, the Program Administrator will determine whether changes to the Program, including the listing of Red Flags, are warranted.
The Program Administrator shall confer with appropriate University personnel as necessary to ensure compliance with the Program. The Program Administrator or his designee shall annually report to the President's staff on the effectiveness of the Program. The Program Administrator shall present any recommended changes to the President's staff for approval. The President's Staff approval shall be sufficient to make changes to the Program.
In order to identify relevant Red Flags, the University considers the types of accounts that it offers and maintains, the methods it provides to open its accounts, the methods it provides to access its accounts, and its previous experiences with Identity Theft. The following are relevant Red Flags, in each of the listed categories, which University personnel should be aware of and diligent in monitoring for:
A. Notifications and Warnings from Credit Reporting Agencies
B. Suspicious Documents
C Suspicious Personal Identifying Information
D. Suspicious Account Activity or Unusual Use of Account
E. Alerts from Others
The Program's general Red Fag detection practices are described in this document. The Identity Theft Prevention Program Committee will develop and implement specific methods and protocols appropriate to meet the requirements of this Program.
A. New Accounts
In order to detect any of the Red Flags identified above associated with the opening of a new account, University personnel will take appropriate steps to obtain and verify the identity of the person opening the account. Such steps may include the following:
B. Existing Accounts
In order to detect any of the Red Flags identified above for an existing account, University personnel will take appropriate steps to monitor transactions with an account. Such steps may include the following:
In the event University personnel detect any identified Red Flags, such personnel shall take appropriate steps to respond and mitigate identity theft depending on the nature and degree of risk posed by the Red Flag, including but not limited to the following examples:
In the event the University engages a service provider to perform an activity in connection with one or more accounts, the University will take appropriate 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. Such steps may include the following:
University personnel responsible for implementing the Program shall be trained under the direction of the Program Administrator or his designee and/or members of the Identity Theft Prevention Committee, as appropriate, in the detection of Red Flags, and the responsive steps to be taken when a Red Flag is detected. Appropriate staff shall provide reports to the Program Administrator on incidents of identity theft, the effectiveness of the Program and the University's compliance with the Program.
All programs implemented pursuant to this policy must be in compliance with FTC regulations, state laws and other University policies.
Adopted 6/08/09 BC