5.15 Identity Theft Prevention Standard - Red Flags Rule
Identity theft is defined as a fraud committed or attempted using the identifying information of another person without authority. The risk to USG institutions, the USO, the GPLS, and the Georgia Archives and their faculty, staff, students, and other applicable constituents from identity theft and accompanying data loss is of significant concern to the USG. USG participant organizations should make reasonable efforts to detect, prevent, and mitigate identity theft.
The USG adopts this Identity Theft Prevention Standard and enacts this program in an effort to detect, prevent and mitigate identity theft, and to help protect USG participant organizations and their faculty, staff, students, and other applicable constituents from damages related to the loss or misuse of identifying information due to identity theft.
Personal identifying information, as defined in Section 5.7 of this Handbook, is any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including but not limited to: name, address, telephone number, Social Security number (SSN), date of birth, government-issued driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, computer Internet Protocol address or routing code, and credit card number or other credit card information.
Under this standard, the program will:
- Identify patterns, practices or specific activities (red flags) that could indicate the existence of identity theft with regard to new or existing covered accounts. A covered account is defined as:
- Any account that involves or is designated to permit multiple payments or transactions; or,
- Any other account maintained by a USG participant organization for which there is a reasonably foreseeable risk of identity theft to students, faculty, staff, or other applicable constituents, or for which there is a reasonably foreseeable risk to the safety or soundness of the USG participant organization from identity theft, including financial, operational, compliance, reputation, or litigation risks.
- Detect red flags that are incorporated in the program. A red flag is a pattern, practice or specific activity that indicates the possible existence of identity theft.
- Respond appropriately to any red flags that are detected under this program to prevent and mitigate identity theft.
- Ensure periodic updating of the program, including reviewing the covered accounts and the identified red flags that are part of this program.
- Promote compliance with state and federal laws and regulations regarding identity theft protection.
The program shall, as appropriate, incorporate existing USG and institutional policies and guidelines such as anti-fraud programs and information security programs that control reasonably foreseeable risks.
5.15.2 Identifying Red Flags
The following examples of red flags are potential indicators of fraud or identity theft. The risk factors for identifying relevant red flags include the types of covered accounts offered or maintained, the methods provided to open or access covered accounts, and previous experience with identity theft. Any time a red flag or a situation closely resembling a red flag is apparent, it should be investigated for verification.
22.214.171.124 Alerts, Notifications, or Warnings from a Credit or Consumer Reporting Agency
Examples of these red flags include:
- A report of fraud or active duty alert in a credit or consumer report
- A notice of credit freeze from a credit or consumer reporting agency in response to a request for a credit or consumer report
- A notice of address discrepancy in response to a credit or consumer report request
- A credit or consumer report having a pattern of activity inconsistent with the history and usual pattern of activity of an applicant, such as:
- A recent and significant increase in the volume of inquiries
- An unusual number of recently established credit relationships
- A material change in the use of credit, especially with respect to recently established credit relationships
- An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor
126.96.36.199 Suspicious Documents
Examples of these red flags include:
- Documents provided for identification appear to have been altered, forged or are inauthentic.
- The photograph or physical description on the identification document is not consistent with the appearance of the individual presenting the identification.
- Other information on the identification is not consistent with information provided by the person opening a new covered account or individual presenting the identification.
- Other information on the identification is not consistent with readily accessible information that is on file with the USG participant organization, such as a signature card or a recent check.
- An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
188.8.131.52 Suspicious Personal Identifying Information
Examples of these red flags include:
- Personal identifying information provided is inconsistent when compared against other sources of information used by the participant organization, such as:
- The address does not match any address in the consumer report; or,
- The SSN has not been issued or is listed on the Social Security Administration’s Death Master File.
- Personal identifying information provided by the individual is not consistent with other personal identifying information provided by that individual, such as a lack of correlation between the SSN range and date of birth.
- Personal identifying information provided is associated with known fraudulent activity, such as the address or telephone number on an application is the same as one provided on a fraudulent application.
- Personal identifying information provided is of a type commonly associated with fraudulent activity, such as:
- The address on an application is fictitious, a mail drop, or a prison; or,
- The phone number is invalid or is associated with a pager or answering service.
- The Social Security number provided is the same as that submitted by another person opening an account.
- The address or telephone number provided is the same as or similar to the address or telephone number submitted by that of another person.
- The individual opening the covered account fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
- Personal identifying information provided is not consistent with personal identifying information that is on file with the USG participant organization.
- When answering security questions (mother’s maiden name, pet’s name, etc.), the person opening that covered account cannot provide authenticating information beyond what would generally be available from a wallet or consumer report.
184.108.40.206 Unusual Use of, or Suspicious Activity Related to, a Covered Account
Examples of these red flags include:
- Shortly following the notice of a change of address for a covered account, a request is received for a new, additional, or replacement card, or for the addition of authorized users on the account.
- A covered account is used in a manner that is not consistent with established patterns of activity on the account, such as:
- Nonpayment when there is no history of late or missed payments; or,
- A material change in purchasing or usage patterns.
- A covered account that has been inactive for a reasonably lengthy period of time is used, taking into consideration the type of account, the expected pattern of usage and other relevant factors.
- Mail sent to the individual is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the individual’s covered account.
- The USG participant organization is notified that the individual is not receiving paper account statements.
- The USG participant organization is notified of unauthorized charges or transactions in connection with an individual’s covered account.
- The USG participant organization receives notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with its covered accounts.
- The USG participant organization is notified by an employee or student, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.
- There is a breach in the USG entity’s computer security system.
5.15.3 Detecting Red Flags
220.127.116.11 Student Enrollment
In order to detect red flags associated with the enrollment of a student, the USG participant organization will take the following steps to obtain and verify the identity of the individual opening the account:
- Require certain identifying information such as name, date of birth, academic records, home address, or other identification; and,
- Verify the student’s identity at the time of issuance of the student identification card through review of a driver’s license or other government-issued photo identification.
18.104.22.168 Existing Accounts
In order to detect red flags associated with an existing account, the USG participant organization will take the following steps to monitor transactions on an account:
- Verify the identification of students if they request information;
- Verify the validity of requests to change billing addresses by mail or email, and provide the student a reasonable means of promptly reporting incorrect billing address changes; and,
- Verify changes in banking information given for billing and payment purposes.
22.214.171.124 Consumer/Credit Report Requests
In order to detect red flags for an employment or volunteer position for which a credit or background report is sought, the USG participant organization will take the following steps to assist in identifying address discrepancies:
- Require written verification from any applicant that the address provided by the applicant is accurate at the time the request for the credit report is made to the consumer reporting agency; and,
- In the event that notice of an address discrepancy is received, verify that the credit report pertains to the applicant for whom the requested report was made and report to the consumer reporting agency an address for the applicant that has reasonably been confirmed is accurate.
5.15.4 Responding to Red Flags
Once a red flag or potential red flag is detected, the USG participant organization must act quickly with consideration of the risk posed by the red flag. The USG participant organization should quickly gather all related documentation, write a description of the situation, and present this information to the Program Administrator for determination. The Program Administrator will complete additional authentication to determine whether the attempted transaction was fraudulent or authentic. The USG participant organization may take any of the following steps deemed appropriate:
- Continue to monitor the covered account for evidence of identity theft.
- Contact the student or applicant for whom a credit report was run.
- Change any passwords or other security devices that permit access to covered accounts.
- Close and reopen the account.
- Determine not to open a new covered account.
- Provide the student with a new student identification number.
- Notify law enforcement.
- Determine that no response is warranted under the particular circumstances.
- Cancel the transaction.
5.15.5 Protecting Personal Information
In order to prevent the likelihood of identity theft occurring with respect to covered accounts, the USG participant organizations may take the following steps with respect to its internal operating procedures:
- Lock file cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with covered account information when not in use.
- Lock storage rooms containing documents with covered account information and record retention areas at the end of each workday or when unsupervised.
- Clear desks, workstations, work areas, printers and fax machines, and common shared work areas of all documents containing covered account information when not in use.
- Destroy documents or computer files containing covered account information in a secure manner.
- Note: Records may only be destroyed in accordance with the state’s records retention guideline.
- Ensure that office computers with access to covered account information are password protected.
- Ensure that the endpoint is secure.
- Avoid the use of Social Security numbers.
- Use encryption devices when transmitting covered account information.
USG personnel are encouraged to use common sense judgment in securing covered account information to the proper extent. Furthermore, this section should be read in conjunction with the Family Education Rights and Privacy Act (FERPA), the Georgia Open Records Act, and other applicable laws and policies. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact his/her supervisor or USG Information & ePrivacy for advice.
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