红旗
董事会政策.16
日期2021年12月
取代: 2014年6月，2009年6月
目的
As defined in Part 681 of Title 16 of the Code of Federal Regulations implementing Sections 114 and 315 of the Fair and Accurate Credit Transactions Act (FACTA) of 2003, the Federal Trade Commission (FTC) mandates that 蒙哥马利县社区学院 implement a written 红旗 Program. The purpose of this policy is to provide guidance in the proper identification, detection, and response to warning signs of identity theft as required by these regulations.
This policy is subject to review and revision, pursuant to corresponding changes in FACTA法律和FTC法规.
范围
This policy applies to all 蒙哥马利县社区学院 covered accounts, both old and new, that offer credit, or other forms of deferred payment (e.g.、递延 payment accounts, refund of credit balances, emergency loans). 此外，政策 applies to all administrators and staff who work with the authentication of persons in the enrollment and management of covered accounts.
政策
In compliance with federal law, 蒙哥马利县社区学院 will develop, implement, and maintain a written 红旗 Program. 红旗计划将识别 red 旗帜, detect the occurrence of red 旗帜, outline appropriate actions for when red 旗帜 are found, and be reevaluated in order that the 政策 remain sufficiently up-to-date to ensure protection against identity theft. 所有承保账户将 have administrative and/or technical controls in place to detect and respond to red 旗帜 that could indicate identity theft.
过程
As part of 蒙哥马利县社区学院’s 红旗 Program, the College will:
- Incorporate operating procedures which address the identification, detection, and response to reasonably foreseeable red 旗帜;
- Train the appropriate staff on how to detect and respond to red 旗帜;
- Take steps to ensure that the activity of any third-party service provider is conducted in accordance with reasonable policies and procedures which comply with regulations mandated by the FTC regarding identity theft prevention;
- Review and update the program on an annual basis, as per the regulations, and update 在必要的时候.
角色和职责
Following approval of the 红旗 政策, the 校董会 delegates responsibility of the 红旗 Program to the Vice President of Finance.
The Vice President of Finance is responsible for the development, implementation, and continued administration of the 红旗 Program. 此外，副总统 of Finance is responsible for identifying new applications of the policy when systems and/or processes include applicable covered accounts and for training applicable staff on detection of and response to the defined red 旗帜 身份盗窃 for each account 适用于此策略的类型. The 红旗 Program will be reviewed on an annual basis (August of each year) to ensure compliance to the FTC regulations. 审查 will include material matters related to the program, and evaluate the effectiveness of the program, significant issues regarding identity theft, management’s response, and a recommendation as to how to improve the program. 文档将被创建， revised, updated, expanded, or depreciated as necessary. 董事会将会 be informed of the result of the annual review.
The Vice President of Information Technology and 制度的有效性 in conjunction with the Executive Director of Information Technology Security is responsible for providing assistance in implementing technical controls to detect and respond to red 旗帜.
定义
身份盗窃 is a fraud committed or attempted using the identifying information of another person.
担保帐户 is an account that a financial institution or creditor offers or maintains, primarily for personal, family, or household purposes, which involves or is designed to permit 多重支付或交易. Accounts for tuition deferred payments are also 考虑承保帐户.
危险信号 is a pattern, practice, or specific activity that indicates the possible existence 身份盗窃.