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<br />6. An address or phone number presented that is the same as that of another <br />person; <br />7. A person fails to provide complete personal identifying information on <br />an application when reminded to do so (however, by law social security <br />numbers may be required); and <br />8. A person's identifying information is not consistent with the information <br />that is on file for the customer. <br />D. Suspicious Account Activity or Unusual Use of Account Red Flags <br />1. Change of address for an account followed by a request to change the <br />account holder's name; <br />2. Payments stop on an otherwise consistently up-to-date account; <br />3. Account used in a way that is not consistent with prior use (example: <br />very high activity); <br />4. Mail sent to the account holder is repeatedly returned as undeliverable; <br />5. Notice to the County that a customer is not receiving mail sent by the <br />County; <br />6. Notice to the County an account has unauthorized activity; <br />7. Breach in the County's computer system security; and <br />8. Unauthorized access to or use of customer account information. <br />9. Two or more returned checks received within a 30 day period from the <br />same customer. <br />E. Alerts from Others Red Flags <br />1. Notice to the County from a customer, identity theft victim, law <br />enforcement or other person that it has opened or is maintaining a <br />fraudulent account for a person engaged in Identity Theft. <br />VI. Detection of Red Flags: <br />A. New Accounts: In order to detect any of the Red Flags identified above <br />associated with the opening of a new account, County personnel will take the <br />following steps to obtain and verify the identity of the person opening the <br />account: <br />I. As a precondition to opening a covered account in the County, each <br />applicant shall provide certain personal identifying information such as <br />name, date of birth, residential or business address, principal place of <br />business for an entity, driver's license or other identification; <br />2. County Staff shall verify the customer's identity (for instance, review a <br />driver's license or other identification card) or review documentation <br />showing the existence of a business entity; <br />3. Each account shall be assigned an account number or customer <br />identification number (CIN) which shall be unique to that account. The <br />Draft <br />Identity Theft Prevention Program Policy <br />Page 4 of 8 <br />