Resolution 2009-15 - Laserfiche WebLink

Home Browse Search

3. Notify law enforcement of possible identity theft; or 4. Take other appropriate action to prevent or mitigate identity theft. Updating the Program The City Council shall annually review and, as deemed necessary by the Council, update the Identity Theft Prevention Program along with any relevant red flags in order to reflect changes in risks to customers or to the safety and soundness of the City and its covered accounts from identity theft. In so doing, the City Council shall consider the following factors and exercise its discretion in amending the program: 1. The City's experiences with identity theft; 2. Updates in methods of identity theft; 3. Updates in customary methods used to detect, prevent, and mitigate identity theft; 4. Updates in the types of accounts that the City offers or maintains; and 5. Updates in service provider arrangements. Program Administration The Finance Director is responsible for oversight of the program and for program implementation. The City Manager is responsible for reviewing reports prepared by staff regarding compliance with red flag requirements and with recommending material changes to the program, as necessary in the opinion of the City Manager, to address changing identity theft risks and to identify new or discontinued types of covered accounts. Any recommended material changes to the program shall be submitted to the City Council for consideration. 1. The Finance Director will report to the City Manager at least annually, on compliance with the red flag requirements. The report will address material matters related to the program and evaluate issues such as: a. The effectiveness of the policies and procedures of the City in addressing the risk of identity theft in connection with the opening of covered accounts and with respect to existing covered accounts; b. Service provider arrangements; c. Significant incidents involving identity theft and management's response; and d. Recommendations for material changes to the Program. 2. The Finance Director is responsible for providing training to all employees responsible for or involved in opening a new covered account or accepting payment for a covered account with respect to the implementation and requirements of the Identity Theft Prevention Program. The Finance Director shall exercise his or her discretion in determining the amount and substance of training necessary. Outside Service Providers In the event that the City engages a service provider to perform an activity in connection with one or more covered accounts, the Finance Director shall exercise his or her discretion in reviewing such arrangements in order to ensure, to the best of his or her ability, that the service provider's activities are conducted in accordance with policies and procedures, agreed upon by contract, that are designed to detect any red flags that 7s