NORTHFIELD BOARD OF EDUCATION FILE CODE: 3250.1
Northfield, New Jersey
IDENTITY THEFT PREVENTION PROGRAM
IN COVERED FINANCIAL ACCOUNTS
If the district maintains certain covered financial accounts pursuant to federal legislation, the district may include the additional program details.
A. Covered financial accounts
A covered financial account includes any account that involves or is designed to permit multiple payments or transactions. Every new and existing account that meets the following criteria is covered by this program:
1. Business, personal and household accounts for which there is a reasonably foreseeable risk of identity theft; or
2. Business, personal and household accounts for which there is a reasonably foreseeable risk to the safety or soundness of the district from identity theft, including financial, operational, compliance, reputation, or litigation risks.
B. Red Flags
1. The following red flags are potential indicators of fraud. Any time a red flag, or a situation closely resembling a red flag, is apparent, it should be investigated for verification:
a. Alerts, notifications or warnings from a consumer reporting agency;
b. A fraud or active duty alert included with a consumer report;
c. A notice of credit freeze from a consumer reporting agency in response to a request for a consumer report; or
d. A notice of address discrepancy from a consumer reporting agency as defined in §334.82(b) of the Fairness and Accuracy in Credit Transactions Act.
2. Red flags also include consumer reports that indicate a pattern of activity inconsistent with the history and usual pattern of activity of an applicant or customer, such as:
a. A recent and significant increase in the volume of inquiries;
b. An unusual number of recently established credit relationships;
c. A material change in the use of credit, especially with respect to a recently established credit relationship; or
d. An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
C. Suspicious documents
1. Documents provided for identification that appear to have been altered or forged.
2. The photograph or physical description on the identification is not consistent with the appearance of the contractor or vendor presenting the identification.
3. Other information on the identification is not consistent with information provided by the person opening a new covered account or vendor presenting the identification.
4. Other information on the identification is not consistent with readily accessible information that is on file with the district, such as a signature card or a recent check.
5. An application or bid appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
D. Suspicious personal identifying information
1. Personal identifying information provided is inconsistent when compared against external information sources used by the district. For example:
a. The address does not match any address in the consumer report;
b. The Social Security Number (SSN) has not been issued or is listed on the Social Security Administration’s Death Master File; or
c. Personal identifying information provided by the vendor is not consistent with other personal identifying information provided by the vendor. For example, there is a lack of correlation between the SSN range and the date of birth.
2. Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the district. For example, the address on an application or bid is the same as the address provided on a fraudulent application.
3. Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the district. For example:
a. The address on an application or bid is fictitious, a mail drop, or a prison; or
b. The phone number is invalid or is associated with a pager or answering service.
4. The SSN provided is the same as that submitted by another persons application, bid or another vendor.
5. The address or telephone number provided is the same as or similar to the address or telephone number submitted by an unusually large number of other vendors, contractors or applicants.
6. The vendors, contractors or applicant opening the covered account fails to provide all required personal identifying information on an application or bid.
7. Personal identifying information provided is not consistent with personal identifying information that is on file with the district.
8. When using security questions (mother’s maiden name, pet’s name, etc.), the person, vendors, contractors or applicant cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.
E. Unusual use of, or suspicious activity related to, the covered financial account
1. Shortly following the notice of a change of address for a covered account, the district receives a request for new, additional, or replacement goods or services, or for the addition of authorized users on the account.
2. A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns. For example, the vendor fails to make the first payment or makes an initial payment but no subsequent payments.
3. A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example:
a. Nonpayment when there is no history of late or missed payments;
b. A material change in purchasing or usage patterns
4. A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors).
5. Mail sent to the vendors or contractors is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s covered account.
6. The district is notified that the customer is not receiving paper account statements.
7. The district is notified of unauthorized charges or transactions in connection with a vendor’s covered financial account.
8. The district receives notice from vendors, contractors, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered financial accounts held by the district.
9. The district is notified by a vendor, a victim of Identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.
Responding to Red Flags
A. Once potentially fraudulent activity is detected, an employee must act quickly as a rapid appropriate response can protect customers and the district from damages and loss.
1. Gather all related documentation and write a description of the situation. Present this information to the designated authority for determination.
2. The designated authority will complete additional authentication to determine whether the attempted transaction was fraudulent or authentic.
B. If a transaction is determined to be fraudulent, appropriate actions must be taken immediately. Actions may include:
1. Canceling the transaction;
2. Notifying and cooperating with appropriate law enforcement;
3. Determining the extent of liability of the district; and
4. Notifying the actual customer that fraud has been attempted.
A. At periodic intervals or as required, the superintendent shall reevaluate the district’s procedures to determine whether all aspects are up to date and applicable in the current business environment and practices.
B. Periodic reviews will include an assessment of which accounts are covered.
C. As part of the review, red flags may be revised, replaced or eliminated. Defining new red flags may also be appropriate.
D. Actions to take in the event that fraudulent activity is discovered may also require revision to reduce damage to the district and its vendors.
A. Involvement of management
1. The Identity Theft Prevention Program shall not be operated as an extension to existing fraud prevention programs, and its importance warrants the highest level of attention.
2. The Identity Theft Prevention Program is the responsibility of the superintendent. Board approval of the initial plan must be appropriately documented and maintained.
3. Operational responsibility of the program is delegated to the superintendent.
B. Staff Training
1. Staff training shall be conducted for all employees, vendors and contractors for whom it is reasonably foreseeable that they may come into contact with accounts or personally identifiable information that may constitute a risk to the district or its customers.
2. The superintendent is responsible for ensuring identity theft training for all required employees, vendors and contractors.
3. Employees must receive annual training in all elements of this policy.
4. To ensure maximum effectiveness, employees may continue to receive additional training as changes to the program are made.
C. Oversight of service provider arrangements
1. It is the responsibility of the district to ensure that the activities of all service providers are conducted in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity theft.
2. A service provider that maintains its own identity theft prevention program, consistent with the guidance of the red flag rules and validated by appropriate due diligence, may be considered to be meeting these requirements.
3. Any specific requirement should be individually addressed in the appropriate contract arrangements.