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(w) -The City is notified that the customer is not receiving paper account <br />statements. <br />(x) The City is notified of unauthorized charges or transactions in connection <br />with a customer's covered account. <br />(y) The City receives nofice from customers, victims of identity theft, law <br />enforcement authorities, or other persons regarding possible identity theft in <br />connection with covered accounts held by the City. <br />(z) The City is notified by a customer, a victim of identity theft, a law <br />enforcement authority, or any other person that it has opened a fraudulent account <br />for a person engaged in identity theft. <br />5. Employee Red Flag Identification and Training. The employees of the City of <br />Lakewood that interact directly with customers on a day-to-day basis shall have the initial <br />responsibility for monitoring the information and documentation provided by the <br />customer and any third-party service provider in connection with the opening of new <br />accounts and the modification of or access to existing accounts and the detection of any <br />Red Flags that might arise. <br />Management shall see to it that all employees who might be called upon to assist a <br />customer with the opening of a new account or with modifying or otherwise accessing an <br />existing account are properly trained such that they have a working familiarity with the <br />relevant Red Flags identified in this Program so as to be able to recognize any Red Flags <br />that might surface in connection with the transaction. <br />An employee who is not sufficiently trained to recognize the Red Flags identified <br />in this Program shall not open a new account for any customer, modify any existing <br />account or otherwise provide any customer with access to information in an existing <br />account without the direct supervision and specific approval of a management employee. <br />Management employees shall be properly trained such that they can recognize <br />the relevant Red Flags identified in this Program and exercise sound judgment in <br />connection with the response to any unresolved Red Flags that may present themselves in <br />cornectior. with the cpening of a rew account or w ~ modifying or accessing of an <br />existing account. Management employees shall be responsible for making the final <br />decision on any such umesolved Red Flags. <br />The Program Administrator shall establish from time to time a written policy <br />setting forth the manner in which a prospective new customer may apply for service, the <br />information and documentation to be provided by the prospecfive customer in connection <br />with an application for a new utility service account, the steps to be taken by the <br />employee assisting the customer with the application in verifying the customer's identity <br />and the manner in which the information and documentation provided by the customer <br />and any third-party service provider shall be maintained. <br />5 <br />