Policies and Procedures

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LEGAL REQUIREMENTS

Section 114 of the Federal Trade Commission's Fair and Accurate Credit Transactions Act of 2003 created the Red Flags Rule.  This regulation requires the College to have an Identity Theft Prevention Procedure designed to detect, prevent, and mitigate Identity Theft in connection with opening a covered account or existing covered account and to provide administration of the procedure.  The College's procedure must:

  • Identify relevant Red Flags for covered accounts it offers or maintains and incorporate those Red Flags into the program
  • Detect Red Flags that have been incorporated into the procedure
  • Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity Theft
  • Ensure the procedure is updated periodically to reflect changes in risks to students and to the safety and soundness of the creditor from Identity Theft

DEFINITIONS

The following definitions are included as part of this procedure:

  • Identity theft – is fraud committed or attempted using the identifying information of another person without authority.
  • Covered account – is an account that a creditor offers or maintains, primarily for personal, family, or household purposes that involves multiple payments or transactions; and, any other account the College offers or maintains for which there is reasonably foreseeable risk to customers or to the safety and soundness of the College from Identity Theft.
  • Red flag – is a pattern, practice or specific activity that indicates the possible existence of identity theft.
  • Identifying Information – is any name or number that may be used, alone or in conjunction with any other information, to identify a specific person including:  name, address, telephone number, social security number, date of birth, driver license, identification number, alien registration number, government passport, employer or taxpayer identification number, student identification number, computer's Internet Protocol address, or routing code.

COVERED ACCOUNTS

The College has identified the following types of accounts that fall under the definition of covered accounts:

  • Refund of credit balances involving PLUS loans
  • Refund of credit balances without PLUS loans
  • Tuition payment deferments
  • Emergency loans
  • Direct deposit information
  • 1098-T information
  • Wisconsin Tax Refund Intercept Program accounts
  • Delinquent Accounts sent to Collection agency
  • Contracted agreements including third-party arrangements

The College has identified the following types of accounts that fall under the definition of service provider covered accounts:

  • On-line payments, administered by TouchNet, refer to "Oversight of Service Provider Arrangements" on page 5
  • Collection recovery, administered by Credit Bureau Data, refer to "Oversight of Service Provider Arrangements" on page 5

IDENTIFICATION OF RED FLAGS

The following risk factors will be used to identify relevant red flags for covered accounts:

  • The types of covered accounts as identified above
  • The methods provided to open covered accounts, which includes gathering the following information:
    • Admissions application with personally identifying information
    • FAFSA application for financial aid assistance
    • High school transcript, GED, HSED
    • Official test scores, such as ACT, SAT, COMPASS, ACCUPLACER, TABE
    • Letters of recommendation
    • Entrance medical record
    • Medical history
    • Immunization history
    • Insurance card
    • Criminal background check information
    • Driver's license
    • Military Service Records
    • Residency documents
    • Financial Status documentation
    • Post-secondary transcripts
  • The methods used to access covered accounts, which include gathering the following information:
    • Disbursement obtained in person require picture identification
    • Disbursements obtained by mail can only be mailed to an address on file
  • The College's previous history of identity theft

The following Red Flags will be considered:

  • Notifications and Warnings from Credit Reporting Agencies
  • Report of fraud accompanying a credit report
  • Notice of report from a credit agency of a credit freeze on an applicant
  • Notice or report from a credit agency of an active duty alert for an applicant
  • Receipt of a notice of address discrepancy in response to a credit report request
  • Indication from a credit report of activity that is inconsistent with an applicant's usual pattern or activity

Suspicious Documents

  • Identification document or card that appears to be forged, altered or inauthentic
  • The photograph or physical description on the identification is not consistent with the appearance of the student presenting the identification
  • A request for service that appears to have been altered or forged
  • A request made from a non-college issued e-mail account

A request to mail something to an address not listed on the file

Suspicious Identifying Information

  • Identifying information presented that is inconsistent with other information the student provides (example:  inconsistent birth dates)
  • Identifying information presented that is inconsistent with other sources of information (example: address mismatch on personal documents)
  • Identifying information presented that is the same information shown on other applications that were found to be fraudulent
  • Identifying information presented that is consistent with fraudulent activity (example:  invalid phone number or fictitious billing address)
  • Social security number presented that is the same as one given by another person
  • A person fails to provide complete personal identifying information on a deferred payment plan when reminded to do so
  • A person's identifying information is not consistent with the information that is on file for the student

Suspicious Account Activity

  • Account used in a way that is not consistent with prior use
  • Mail sent to the student is repeatedly returned as undeliverable
  • Notice to the College that a student is not receiving mail sent by the College
  • Notice to the College that an account has unauthorized activity
  • Breach in the College's computer security system
  • Unauthorized access to or use of student account information

 Alerts from Others

  • Notice to the College from a student, Identity Theft victim, law enforcement or other person that the College has opened or is maintaining a fraudulent account for a person engaged in Identity Theft

DETECTION OF RED FLAGS

Student Enrollment

In order to detect any of the Red Flags identified above associated with the enrollment of a student, College personnel will take the following steps to obtain and verify the identity of the person 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 time of issuance of student identification card (review government-issued photo identification or other personally identifiable information)

Existing Accounts

In order to detect any of the Red Flags identified above for an existing covered account, College personnel will take the following steps to monitor transactions on an account:

  • Verify the identification of students if they request information (in person, via telephone, via facsimile, via email);
  • 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

Credit Report Requests

In order to detect any of the Red Flags identified above for an employment or volunteer position for which a credit or background report is sought, College personnel 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 the College has reasonably confirmed is accurate.

PREVENTING AND MITIGATING IDENTITY THEFT

When a red flag is triggered, personnel shall take one or more of the following steps, depending on the degree of risk posed by the Red Flag:

Prevent and Mitigate

  • Continue to monitor a covered account for evidence of Identity Theft
  • Contact the student or applicant
  • Change any passwords or other security devices that permit access to covered accounts
  • Not open a new covered account
  • Notify the Program Administrator for determination of the appropriate step(s) to take
  • Notify law enforcement
  • Determine that no response is warranted under the particular circumstances
  • Provide ability to provide FERPA block on directory information

Protect Student Identifying Information

In order to further prevent the likelihood of Identity Theft occurring with respect to covered accounts, the College will take the following steps with respect to its internal operating procedures to protect student identifying information:

  • Ensure that its website is secure or provide clear notice that the website is not secure
  • Ensure complete and secure destruction of paper documents and computer files containing student account information when a decision has been made to no longer maintain such information
  • Ensure that office computers with access to covered account information are password protected
  • Avoid use of social security numbers
  • Ensure computer virus protection is up to date
  • Require and keep only the kinds of student information that are necessary for College purposes
  • Automatic lock-out for computers

PROGRAM ADMINISTRATION

Oversight

The Registrar will serve as the Program Administrator and is responsible for developing, implementing and updating this program.  The Program Administrator will be responsible for ensuring appropriate training of College staff on the program, for reviewing any staff reports regarding the detection of Red Flags and the steps for preventing and mitigating Identity Theft, determining which steps of prevention and mitigation should be taken in particular circumstances and considering periodic changes to the program.

Staff Training and Reports

College staff responsible for implementing the Program shall be trained in the detection of Red Flags and the responsive steps to be taken when a Red Flag is detected.  College staff shall be trained, as necessary, to effectively implement the program. College employees are expected to notify the Program Administrator once they become aware of an incident of Identity Theft or of the College's failure to comply with this program.  At least annually, College staff responsible for development, implementation, and administration of the program shall report to the Program Administrator on compliance with this program.  The report should address such issues as effectiveness of the policies and procedures in addressing the risk of identity theft in connection with the opening and maintenance of covered accounts, service provider agreements, significant incidents involving identity theft and management's response, and recommendations for changes to the program.

Service Provider Arrangements

In the event the College engages a service provider to perform an activity in connection with one or more covered accounts, the College will take the following steps to ensure the service provider performs its activity in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of Identity Theft

  • Require, by contract, that service providers have such policies and procedures in place; and
  • Require, by contract, that service providers review the College's program and report any Red Flags to the Program Administrator

Specific Program Elements and Confidentiality

For the effectiveness of this Identity Theft Prevention Program, knowledge about specific Red Flag identification, detection, mitigation and prevention practices may need to be limited to the committee who developed this program and to those employees with a need to know them.  Any documents that may have been produced or are produced in order to develop or implement this program that list or describe such specific practices and the information those documents contains are considered "confidential" and should not be shared with other College employees or the public.  The Program Administrator shall inform the employees with a need to know the information of those documents or specific practices which should be maintained in a confidential manner.

Program Updates

The Program Administrator will periodically review and update this program to reflect changes in risks to students and the soundness of the College from Identity Theft.  In doing so, the Program Administrator will consider the College's experiences with Identity Theft situations, changes in Identity Theft methods, changes in Identity Theft detection and prevention methods, and changes in the College's business arrangements with other entities.  After considering these factors, the Program Administrator will determine whether changes to the program, including the list of Red Flags, are warranted.  If warranted, the Program Administrator will update the program.

Disclaimer

While reasonable efforts will be made to detect, prevent and mitigate Identify Theft, the College makes no representations or warranties that the Program described above will in fact ensure the absence of Identify Theft or prevent financial losses.  All warranties against loss, both express or implied, are hereby disclaimed.  Furthermore, the College will not be liable for any damages, whether direct, indirect or consequential.


Approved June 16, 2009