§ 2-187. Identify the risks of theft and fraud

(a) The Town of Kure Beach has a responsibility to define high risk areas for identity theft and identify potential threats for identity theft known under the Act as red flags. The red flags are indicators that sensitive information is being fraudulently used. This policy in combination with department-specific guidelines should help to detect a potential for identify theft and unauthorized use of information.

(b) The following are red flags that have been identified as indicators that sensitive information is being used fraudulently. Red flags are most commonly associated with activity on customer accounts (utilities, taxes, vendors). Other red flags may exist that are unique to a department and should be included in departmental guidelines.

(1) The customer or individual provides notice that they are a victim of identify theft.

(2) A consumer reporting agency or service provider has provided an alert, notification, or other warning.

(3) Unusual number of recent and significant inquiries.

(4) Unusual or significant change in recently established credit or financial relationships.

(5) Conflicting names on identification and other documentation.

(6) Documents provided appear to have been altered or forged.

(7) Picture identification is not consistent with the appearance of the individual presenting the identification or the physical description on the identification does not match.

(8) Shortly after establishing an account, there is a request to change a mailing address or to add authorized users to the account.

(9) Personal identifying information provided is not consistent with other external information sources.

a. Social security number does not match or is listed on the Social Security Administration's death master file.

b. Address does not match or is fictitious, a mail drop, or prison.

c. The phone number is invalid or associated with a pager or answering service.

d. Authenticating information (i.e., PIN, password) provided is incorrect.

e. Name on credit card or check does not match name on account or names associated with the account.

(c) Upon identification of a red flag indicating a potential risk of identify theft; staff should notify their immediate supervisor in person or by telephone to determine the validity of the red flag. Once an identify theft risk is confirmed, staff should respond in accordance with the breach response plan (section 2-188).

(Ord. of 10-21-08(1), § 7)