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`3 <br /> I. PROGRAM ADOPTION <br /> The Everett Public Works Department (the "Utility") developed this Identity Theft <br /> Prevention Program(the "Program") pursuant to the Federal Trade Commission's Red Flags <br /> Rule (the "Rule"), which implements Section 114 of the Fair and Accurate Credit Transactions <br /> Act of 2003. Upon the recommendation of the senior management of the Utility, the City <br /> Council approved this Program on May, 1st 2009. <br /> II. PROGRAM PURPOSE AND DEFINITIONS <br /> A. Fulfilling Requirements of the Red Flags Rule <br /> Under the Rule, every financial institution and creditor is required to establish an"Identity <br /> Theft Prevention Program" tailored to its size, complexity and the nature of its operation. Each <br /> program must contain reasonable policies and procedures to: <br /> 1. Identify relevant Red Flags for new and existing covered accounts and incorporate those <br /> Red Flags into the Program; <br /> 2. Detect Red Flags that have been incorporated into the Program; <br /> 3. Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity <br /> Theft; and <br /> 4. Ensure the Program is updated periodically to reflect changes in risks to customers or to <br /> the safety and soundness of the Utility from Identity Theft. <br /> B. Red Flags Rule Definitions Used in this Program <br /> The Rule defines "Identity Theft" as "fraud committed using the identifying information of <br /> another person"and a"Red Flag"as "a pattern, practice, or specific activity that indicates the <br /> possible existence of Identity Theft." <br /> According to the Rule, a municipal utility is a creditor subject to the Rule requirements. The <br /> Rule defines creditors "to include finance companies, automobile dealers, mortgage brokers, <br /> utility companies, and telecommunications companies. Where non-profit and government <br /> entities defer payment for goods or services, they, too, are to be considered creditors." <br /> Many,if not all, of the Utility's accounts that are individual utility service accounts held by <br /> customers of the Utility are covered by the Rule, regardless of whether such accounts are <br /> residential, commercial or industrial. Under the Rule, a"covered account" is: <br /> 1. Any account the Utility offers or maintains primarily for personal, family or household <br /> purposes that involves multiple payments or transactions; and <br /> I <br /> 2 <br />