Draft Fair and Accurate Credit Transaction Act of 2003 FACTA Red Flags Rules Policy 04-21-2009-4n

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~1ltl.l~ T Orange County Identity Theft Prevention Program Policy Purpose. The purpose of this program is to establish an Identity Theft Prevention Program ~"the Program'"} designed to detect, prevent, and mitigate identity theft in connection with opening a covered or existing covered account; responding to such red Bags pattern, practice, or specific activity that indicates the possible existence of identity theft in a manner that will prevent identity theft} and to provide far continued administration of the Program. in compliance with Part X81 of Title ~ of the Code of Federal Regulations implementing Section 114 and 3 S of the Fair and Accurate Credit Transactions Act ~FACTA} of 2~U3. II, Adoption. This Policy was developed by the Identity Theft Prevention Program Committee ~"the Committee"} with oversight by the Grange County Manager and was approved by the Grange County Board of Commissioners. The Committee, after conducting a risk assessment and considering the size and complexity of the County's operations and account systems, and the nature and scope of the County's activities with respect to identity theft, forwarded this Program to the County Manager for review. The County Manager determined this Pragrana was appropriate for Drange County and recommended adoption of this Program to the Board of County Commissioners. The Board of County Commissioners approved adoption of this program on April , 2a~9. III. Program. grange County is establishing an Identity Theft Prevention Program to detect, prevent, and mitigate identity theft. The Program is tailored to C3range County's size, complexity and the nature of operations and includes reasonable policies and procedures to: A. Identify relevant red flags for covered accounts it offers or maintains and incorporate those red flags into the program; B. Detect red flags that have been incorporated into the Program; C. Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and I]. Ensure the Program is updated periodically to reflect changes in risks to customers and to the safety and soundness of the creditor from identity theft. The Program incorporates, as appropriate, existing policies and procedures that control reasonably foreseeable risks of identity theft. IV. Definitions. Far u ores of this Policy, the following definitions shall apply p~ A. "County" means the County of Qrange. ,~ ~ other than "county, personal identifying information and identity theft prevention committee", definitions provided in this section are based on the definitions provided in ~ 6 CSR ~ ~~S 1.Z.