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Personal Identifying Information means a person's credit card account information, <br />debit card information, bank account information and drivers' license information and for <br />a natural person includes their social security number, mother's birth name, and date of <br />birth. <br />Red flag means a pattern, practice, or specific activity that indicates the possible <br />existence of identity theft. <br />Service provider means a person that provides a service directly to the City. <br />Findings <br />The City is a creditor pursuant to 16 CFR § 681.2 due to its provision or <br />maintenance of covered accounts for which payment is made in arrears. <br />2. Covered accounts offered to customers for the provision of City services include <br />water utility, wastewater utility, storm water utility, and solid waste utility accounts. <br />3. The process of opening a new covered account and making payments on such <br />accounts have been identified as potential processes in which identity theft could <br />occur. <br />4. The City limits access to personal identifying information to those employees <br />responsible for or otherwise involved in opening covered accounts or accepting <br />payment for use of covered accounts. Information provided to such employees is <br />entered directly into the City's computer system and is not otherwise recorded. <br />5. The City determines that there is a low risk of identity theft occurring in the following <br />ways: <br />a. Use by an applicant of another person's personal identifying information to <br />establish a new covered account; and <br />b. Use of another person's credit card, bank account, or other method of payment <br />by a customer to pay such customer's covered account or accounts. <br />Process of Establishing a Covered Account <br />As a precondition to opening a covered account in the City, each applicant shall be <br />confirmed by a third party, such as a title company, or shall provide the City with a valid <br />government issued identification card containing a photograph of the applicant. The <br />identifying number of card shall be recorded on the application for service. <br />Access to Covered Account Information <br />Access to customer accounts shall be password protected and shall be limited to <br />authorized City personnel. Any unauthorized access to or other breach of customer <br />accounts is to be reported immediately to the Finance Director and the password <br />changed immediately. Personal identifying information included in customer accounts is <br />considered confidential and any request or demand for such information shall be <br />immediately forwarded to the City Clerk. <br />75 <br />