Identity Theft Policy
Policy Number: 500.004.02
Approved by: Senior Staff
Effective Date: April 2009
Revised: April 2013
The College adopts this sensitive information policy to help protect affiliated parties and the College from damages related to the loss or misuse of sensitive information.
This policy will:
- Define sensitive information;
- Describe the physical security of data when it is printed on paper;
- Describe the electronic security of data when stored and distributed; and
- Place the College in compliance with state and federal law regarding identity theft protection.
This policy enables the College to protect affiliated parties, reducing risk from identity fraud, and minimize potential damage to the College from fraudulent new accounts. The program will help the College:
- Identify risks that signify potentially fraudulent activity within new or existing covered accounts;
- Detect risks when they occur in covered accounts;
- Respond to risks to determine if fraudulent activity has occurred and act if fraud has been attempted or committed; and
- Update the program periodically, including reviewing the accounts that are covered and the identified risks that are part of the program.
The risk to Scripps College (hereafter referred to as “the College”), its students, parents of students, responsible billing party, alumnae, donors, employees, contractors, consultants, temporary workers, and other workers at the college, including all personnel affiliated with third parties (hereafter referred to as “affiliated parties”) from data loss and identity theft is of significant concern to the College and can be reduced only through the combined efforts of employees and contractors.
This policy and protection program applies to all affiliated parties.
1.A: Sensitive Information Policy
1.A.1: Definition of Sensitive Information. Sensitive information includes the following items whether stored in electronic or printed format:
- 1.A.1.a: Credit card information, including any of the following:
- Credit card number (in part or whole)
- Credit card expiration date
- Cardholder name
- Cardholder address
- 1.A.1.b: Tax identification numbers, including:
- Social Security number
- Business identification number
- Employer identification number
- 1.A.1.c: Payroll information, including, among other information:
- Pay stubs
- 1.A.1.d: Financial Aid documentation, including:
- Student and responsible billing party tax returns
- Data provided on financial aid applications
- Additional information provided by the Internal Revenue Service, the Department of Homeland Security and the Department of Justice
- Social Security number
- Tax identification number
- Information regarding citizenship status
- 1.A.1.e: Medical information for any employee or student, including but not limited to:
- Doctor names and claims
- Medical insurance information
- Insurance claims
- Any related personal medical information
- 1.A.1.f: Other personal information belonging to any student, employee or contractor, examples of which include:
- Date of birth
- Phone numbers
- Maiden name
- Customer number
- Alien registration number
- Driver’s license number
- Passport number
- Spouse/domestic partner and/or dependent personal information
- 1.A.1.g: College personnel are encouraged to use common sense judgment in securing confidential information to the proper extent. Furthermore, this section should be read in conjunction with the California Public Records Act. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact his/her supervisor. In the event that the College cannot resolve a conflict between this policy and the California Public Records Act, the College will contact the California Attorney General’s Office.
1.A.2: Hard Copy Distribution.
Each employee and contractor performing work for the College will comply with the following policies:
- Storage spaces and rooms containing documents with sensitive information will be locked at the end of each workday, when not in use and when unsupervised.
- Desks, workstations, work areas, printers and fax machines, and common shared work areas will be cleared of all documents containing sensitive information when not in use.
- Whiteboards, dry-erase boards, writing tablets, etc. in common shared work areas will be erased, removed, or shredded when not in use.
- When documents containing sensitive information are discarded they will be secured until such time that the documents can be properly shredded. College records, however, may only be destroyed in accordance with the document retention policy.
1.A.3: Electronic Distribution.
Each employee and contractor performing work for the college will comply with the following policies:
- Sensitive information is stored on the College’s file servers only, with unique username and password protection.
- Any sensitive information sent externally should be sent securely and only to approved recipients.
Section 2: Additional Identity Theft Prevention Program
If the College maintains certain covered accounts pursuant to federal legislation, the College will include the additional program details.
2.A: Covered accounts
A covered account includes any account that involves or is designed to permit multiple payments or transactions. Every new and existing account that meets the following criteria is covered by this program:
- Business, personal and household accounts for which there is a reasonably foreseeable risk of identity theft; or
- Business, personal and household accounts for which there is a reasonably foreseeable risk to the safety or soundness of the College from identity theft, including financial, operational, compliance, reputation, or litigation risks.
2.B: Red flags
2.B.1: The following red flags are potential indicators of fraud. Any time a red flag, or a situation closely resembling a red flag, is apparent, it should be investigated for verification in a reasonable amount of time.
- Alerts, notifications or warnings from a consumer reporting agency;
- A fraud or active duty alert included with a consumer report;
- A notice of credit freeze from a consumer reporting agency in response to a request for a consumer report; or
- A notice of address discrepancy from a consumer reporting agency as defined in 334.82(b) of the Fairness and Accuracy in Credit Transactions Act.
2.B.2: Red flags also include consumer reports that indicate a pattern of activity inconsistent with the history and usual pattern of activity of an applicant or customer, 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; or
- An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
2.C: Suspicious documents
The following are examples of suspicious documents:
- Documents provided for identification that appear to have been altered or forged;
- The photograph or physical description on the identification is not consistent with the appearance of the affiliated party presenting the identification;
- Other information on the identification is not consistent with information provided by the affiliated party opening a new covered account or presenting the identification;
- Other information on the identification is not consistent with readily accessible information that is on file with the College, such as a signature card or a recent check; or
- An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
2.D: Suspicious personal identifying information
- 2.D.1: Personal identifying information provided is inconsistent when compared against external information sources used by the College, such as:
- The address does not match any known addresses;
- The Social Security number (SSN) has not been issued or is listed on the Social Security Administration’s Death Master File; or
- Personal identifying information provided by the customer is not consistent with other personal identifying information provided by the customer. For example, there is a lack of correlation between the SSN range and date of birth.
- 2.D.2: Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the College, 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.
- 2.D.3: The SSN provided is the same as that submitted by other persons opening an account or other affiliated party.
- 2.D.4: The affiliated party 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.
- 2.D.5: Personal identifying information provided is not consistent with personal identifying information that is on file with the College.
- 2.D.6: When using security questions (mother’s maiden name, pet’s name, etc.), the affiliated party opening the covered account cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.
2.E: Unusual use of, or suspicious activity related to, the covered account
- 2.E.1: In a reasonable amount of time following the notice of a change of address for a covered account, the College receives a request for new, additional, or replacement statements, or for the addition of authorized users on the account.
- 2.E.2: A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example, nonpayment when there is no history of late or missed payments;
- 2.E.3: 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).
- 2.E.4: Mail sent to the affiliated party is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s covered account.
- 2.E.5: The College is notified that the affiliated party is not receiving paper account statements.
- 2.E.6: The College is notified of unauthorized charges or transactions in connection with a covered account.
- 2.E.7: The College receives notice from affiliated parties, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the College
- 2.E.8: The College is notified by an affiliated party, 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.
Section 3: Responding to Red Flags
- 3.A: Once potentially fraudulent activity is detected, an employee should make a good faith effort to respond as a rapid appropriate response can protect customers and the College from damages and loss.
- 3.A.1: Once potentially fraudulent activity is detected, gather all related documentation and write a description of the situation. Present this information to your immediate supervisor for determination with a copy being provided to the Treasurer and the senior staff member who oversees the department. If it is determined that follow up and additional investigation is needed, a copy should be provided to the President.
- 3.A.2: The supervisor and senior staff member will complete additional authentication to determine whether the attempted transaction was fraudulent or authentic. The results of that determination should be provided to the Treasurer.
- 3.B: If a transaction is determined to be fraudulent, appropriate action is to be taken in a reasonable amount of time. Actions may include:
- Canceling the transaction;
- Notifying and cooperating with appropriate law enforcement;
- Determining the extent of liability of the College; and
- Notifying the affiliated party that fraud has been attempted.
Section 4: Periodic Updates to Plan
- 4.A: At periodic intervals established in the program, or as required, the program will be re- evaluated to determine whether all aspects of the program are up to date and applicable in the current business environment.
- 4.B: Periodic reviews will include an assessment of which accounts are covered by the program.
- 4.C: As part of the review, red flags may be revised, replaced or eliminated. Defining new red flags may also be appropriate.
- 4.D: Actions to take in the event that fraudulent activity is discovered may also require revision to the policy to reduce damage to the College and its affiliated parties.
Section 5: Program Administration
- 5.A: Involvement of management
- The Identity Theft Prevention Program warrants the highest level of attention.
- The Identity Theft Prevention Program is reviewed and approved of the Board of Trustees. Approval of the initial plan is appropriately documented in the minutes of the Executive Committee of the Board of Trustees and maintained in the Office of the Treasurer.
- Operational responsibility of the program is delegated to the Office of the Treasurer.
- 5.B: Staff training. Staff training shall be conducted for all employees, officials and contractors, as necessary, for whom it is reasonably foreseeable that they may come into contact with accounts or personally identifiable information that may constitute a risk to the College or its affiliated parties. Appropriate staff are required to become familiar with the guidelines of this program during orientation, training and periodically thereafter.
- 5.C: Oversight of service provider arrangements
- The College will require all service providers be compliant with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft.
- A service provider that maintains its own identity theft prevention program, consistent with the guidance of the red flag rules and validated by appropriate due diligence, may be considered to be meeting these requirements.
- Any specific requirements should be specifically addressed in the appropriate contract arrangements.