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9. Duties Regarding Address Discrepancies. In the event the City uses a consumer <br />report and receives a notice from a consumer reporting agency of an address discrepancy, <br />the appropriate employee shall establish that the consumer report relates to the consumer <br />about whom the City has requested the consumer report. This may be done by: <br />verification of the address with the consumer; review of the utility's records; verification <br />of the address through third-party sources; or other reasonable means. <br />10. Updating Program. This Program shall be updated periodically to reflect changes <br />in risks to customers or to the safety and soundness of the organization from identity theft <br />based on factors such as: the experiences of the organization with identity theft; changes <br />in methods of identity theft; changes in methods to detect, prevent and mitigate identity <br />theft; changes in the types of accounts that the organization offers or maintains; changes <br />in the business arrangements of the organization, including mergers, acquisitions, <br />alliances, joint ventures and service provider arrangements. <br />11. Oversight of Program. The Program Coordinator shall oversee and take steps to <br />ensure that this Program is being followed. Oversight of this Program shall include: <br />assignment of specific responsibility for implementation of this Program; review of <br />reports prepared by staff regarding compliance; and approval of material changes to this <br />Program as necessary to address changing risks of identity theft. The reports by staff shall <br />address material matters related to the Program and evaluate issues such as: the <br />effectiveness of the program in addressing the risk of identity theft in connection. with the <br />opening of covered accounts and with respect to existing covered accounts; significant <br />incidents involving identity theft and the City's response; and recommendations for <br />material changes to the Program. The Program Coordinator shall train staff, as necessary, <br />to effectively implement the Program. The Program Coordinator shall also oversee any <br />service provider arrangements in the event the City engages a service provider to perform <br />an activity in connection with one or more covered accounts to assure that the activity of <br />the service provider is conducted in accordance with this Program and any reasonable <br />policies and procedures designed to detect, prevent, and mitigate the risk of identity theft. <br />12. Responsibility. The initial adoption and approval of the Identity Theft <br />Prevention Program shall be by Resolution as adopted by City Council. Thereafter, <br />changes to the Program of a day-to-day operational character and decisions relating to the <br />interpretatior. and implementaticn of the Program may be made by the Identity Theft <br />Prevention Program Committee. Major changes or shifts of policy positions under the <br />Program shall only be made with the approval of the Mayor. Development, <br />implementation, administration, and oversight of the Program will be the responsibility of <br />the Program Administrator. The Program Administrator may, but shall not be required <br />to, appoint a committee to administer the Program. The Program Administrator shall be <br />the head of any such committee. The Program Administrator will report at least annually <br />to the Mayor and City Council regarding compliance with this Program. <br />7 <br />