The following Procedures are established under the University Identity Theft Prevention Program Policy (“Policy”) and apply to the Illinois State University Identity Theft Prevention Program (“Program”). It is the responsibility of all Administrators, Deans, Directors, Department Heads, Fiscal Agents and Data Custodians to ensure compliance with these Procedures and the Program as established by the Policy.
University areas specifically identified as falling within the Red Flags criteria are listed below; however, this list is not exhaustive and there may be other offices to which the Red Flag rules apply. Offices required to comply with the Red Flags criteria include but are not limited to:
“Identity Theft” is a fraud committed or attempted using the identifying information of another person without authority.
“Red Flag” is a pattern, practice, or specific activity that indicates the possible existence of identity theft.
“Creditor” is any person who defers payments for services rendered, such as an organization that bills at the end of the month for services rendered the previous month.
“Covered Account” includes all accounts or loans that are administered by the University that involve multiple payments or transactions such as a loan that is billed monthly throughout the semester rather than requiring full payment at the beginning of the semester.
“Program Administrator” is the individual designated by this policy with primary responsibility for oversight of the University Identity Theft Prevention Program.
“Identifying information” is any name or number that may be used, alone or in conjunction with any other information, to identify a specific person. This includes name, address, telephone number, social security number, 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’s Internet Protocol address, or routing code.
Under the Red Flags Rule, the University is required to establish an “Identity Theft Prevention Program” tailored to its size, complexity and the nature of its operation. Each program must contain reasonable policies and procedures to:
In order to identify relevant Red Flags, the University must consider the types of accounts that it offers and maintains, methods it provides to open its accounts, methods it provides to access its accounts, and its previous experiences with identity theft. The University has identified the following Red Flags including but not limited to those listed in the following categories:
In order to detect any of the Red Flags identified above associated with the enrollment of a student or the hiring of a University employee, University personnel will take the following steps to obtain and verify the identity of the person opening the account:
In order to detect any of the Red Flags identified above for an existing covered account, University personnel will take the following steps to monitor transactions on an account:
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, University personnel will take the following steps to assist in identifying address discrepancies:
In the event University personnel detect any identified Red Flags, such personnel shall take one or more of the following steps, depending on the degree of risk posed by the Red Flag:
In order to further prevent the likelihood of Identity Theft occurring with respect to covered accounts, the University will take the following steps with respect to its internal operating procedures to protect personal identifying information:
Responsibility for developing, implementing and updating the University Identity Theft Prevention Program lies with the Illinois State University Identity Theft Committee. The Committee will be headed by a Program Administrator(s) who is the individual(s) designated by this policy with primary responsibility for oversight of the University Identity Theft Prevention Program. The President of the University or his or her designee will appoint the Program Administrator. Two or more other individuals appointed by the President or the Program Administrator shall comprise the remainder of the Committee membership.
The Program Administrator will be responsible for ensuring appropriate training of University 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. The University Identity Theft Committee will periodically review and update this Program to reflect changes in risks and in the soundness of the University from identity theft.
University staff responsible for implementing the Program shall be trained either by or under the direction of the Program Administrator in the detection of Red Flags and the responsive steps to be taken when a Red Flag is detected. University staff shall be trained, as necessary, to effectively implement the Program. University employees are expected to notify the Program Administrator once they become aware of an incident of identity theft or of the University’s failure to comply with this Program.
At least annually or as otherwise requested by the Program Administrator, University 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 arrangements, and significant incidents involving identity theft and management’s response, and recommendations for changes to the Program.
In the event the University engages a service provider to perform an activity in connection with one or more covered accounts, the University will take the following steps to ensure the service provider performs its activity in accordance with the policies and procedures designed to detect, prevent and mitigate the risk of identity theft.
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 develops 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 contain are to be considered “confidential” and should not be shared with others. The Program Administrator shall inform the Committee and those employees with a need to know the information of those documents or specific practices which should be maintained in a confidential manner.
Initiating body: Office of the President
Contact: Program Administrator (309-438-5677)
Created on: 04/2009