This policy establishes a program to detect, prevent and respond to “Red Flags” which could signal potential identity theft in connection with information maintained by or in the possession of The College of Wooster. It supplements our existing policies that protect student information and records, employee information, financial accounts, information technology services, and related sensitive information maintained by the College. This policy was established to comply with the provisions of the Federal Trade Commission’s (“FTC”) regulations on “Identity Theft Red Flags and Address Discrepancies under the Fair and Accurate Credit Transactions Act (FACTA) of 2003”(‘Red Flags Rule’). Applicability of these regulations was extended to non-profit entities in July 2008 when the FTC stated that “where non-profits and government entities defer payment for goods or services, they, too, are to be considered ‘creditors’.”

Section 1: Background

The risk to the College, its employees, students and customers from data loss and identity theft is of significant concern to the College and can be reduced only through the combined efforts of every employee.

Section 2: Purpose

The College adopts this identity theft policy to help protect employees, students, prospective students, alumni, donors, customers, contractors, and the College from damages related to the loss or misuse of sensitive information.

This policy will:

• Define sensitive information.
• Describe the physical security of data when it is printed on paper.
• Describe the electronic security of data when stored and distributed; and
• Place the College in compliance with federal law regarding identity theft protection.

This policy enables the College to protect existing customers, reducing risk from identity fraud, and minimize potential damage to the College from fraudulent new accounts. The program will help the College:

• Identify risks that signify potentially fraudulent activity within new or existing covered accounts.
• Detect risks when they occur in covered accounts.
• Respond to risks to determine if fraudulent activity has occurred and act if fraud has been attempted or committed; and
• Update the program periodically, including reviewing the accounts that are covered and the identified risks that are part of the program.

Section 3: Scope

This policy and protection program applies to employees, students, contractors, consultants, temporary workers, and other workers at the College, including all personnel affiliated with third parties.

Section 4: Policy

Sensitive Information Policy

Definition of Sensitive Information: Sensitive information includes the following items whether stored in electronic or printed format:

• Credit/payment card information, including any of the following:
  • Credit card number (in part or whole)
  • Credit card expiration date
  • Cardholder name
  • Cardholder address
  • Three digit security information
    
    
• Identification numbers and other information used for identification purposes, including:
  • Social Security number or EU identification number
  • Business identification number
  • Employer identification numbers
  • Drivers’ license numbers
  • Customer numbers
  • Date of birth
    
    
• Payroll information, including, among other information:
  • Paychecks
  • Pay stubs
  • Pay advices
    
    
• Cafeteria plan check requests and associated paperwork

• Medical information for any employee or customer, including but not limited to:
  • Health provider names and claims
  • Insurance claims
  • Prescriptions
  • Any related personal medical information

• Electronic transfer information including:
  • Account number
  • Routing number
    
    
• Personal check information including:
  • Account number
  • Routing number
  • Signature

College personnel are encouraged to use common sense judgment in securing confidential information to the proper extent. If an employee is uncertain of the sensitivity of a particular piece of information, they should contact their supervisor.

Hard Copy Distribution

Each employee and contractor performing work for the College will comply with the following procedures:

• File cabinets, desk drawers, overhead cabinets, and any other storage space containing documents with sensitive information will be locked when not in use.
• Storage rooms containing documents with sensitive information and record retention areas will be locked at the end of each workday or when unsupervised.
• Desks, workstations, work areas, printers and fax machines, and common shared work areas will be cleared of all documents containing sensitive information when not in use.
• Whiteboards, dry-erase boards, writing tablets, etc., containing sensitive information, in common shared work areas will be erased, removed, or shredded when not in use.
• When documents containing sensitive information are discarded they will be placed inside a locked shred bin or immediately shredded using a mechanical shredder. College records, however, may only be destroyed in accordance with the College’s records retention policy.

Electronic Distribution

Each employee and contractor performing work for the College will comply with the following policies:

• All sensitive information stored outside central administrative software systems must be encrypted. This includes any sensitive information stored on laptop hard disks. It also includes any sensitive information stored on floppy disks, USB keys or any other portable media.
• Any sensitive information sent via email must be encrypted and password protected and sent only to approved recipients. Additionally, a statement such as this should be included in the e-mail: “This message may contain confidential and/or proprietary information and is intended for the person/entity to whom it was originally addressed. Any use by others is strictly prohibited.”

Section 5: Additional Identity Theft Prevention Program

Covered accounts

A covered account includes any consumer account that involves or is designed to permit multiple payments or transactions. Every new and existing customer account that meets that criterion is covered by this program.

Red flags

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.

• Alerts, notifications or warnings from a consumer reporting agency;
• A fraud or active-duty alert included with a consumer report;
• A notice of credit freeze from a consumer reporting agency in response to a request for a consumer report; or
• 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.

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 recent and significant increase in the volume of inquiries;
• An unusual number of recently established credit relationships;
• A material change in the use of credit, especially with respect to recently established credit relationships; or
• An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.

Suspicious documents

• Documents provided for identification that appear to have been altered or forged.
• The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification.
• Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification.
• Other information on the identification is not consistent with readily accessible information that is on file with the College, such as a signature card or a recent check.
• An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.

Suspicious personal identifying information

• Personal identifying information provided is inconsistent when compared against external information sources used by the College. For example:
  • The address does not match any address in the consumer report;
  • The Social Security number (SSN) has not been issued or is listed on the Social Security Administration’s Death Master File; or
  • Personal identifying information provided by the customer is not consistent with other personal identifying information provided by the customer. For example, there is a lack of correlation between the SSN range and date of birth.
• Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the College. For example, the address on an application is the same as the address provided on a fraudulent application
• Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the College. For example:
  • The address on an application is fictitious, a mail drop, or a prison; or
  • The phone number is invalid or is associated with a pager or answering service.
• The SSN provided is the same as that submitted by other persons opening an account or other customers.
• 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 customers or other persons opening accounts.
• The customer or the person opening the covered account fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
• Personal identifying information provided is not consistent with personal identifying information that is on file with the College.
  

Unusual use of, or suspicious activity related to, the covered account

• Shortly following the notice of a change of address for a covered account, the College receives a request for new, additional, or replacement goods or services, or for the addition of authorized users on the account.
• A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns. For example, the customer fails to make the first payment or makes an initial payment but no subsequent payments
• A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example:
  • Nonpayment when there is no history of late or missed payments;
  • A material change in purchasing or usage patterns
• 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).
• Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s covered account.
• The College is notified that the customer is not receiving account statements.
• The College is notified of unauthorized charges or transactions in connection with a customer’s covered account.
• The College receives notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the College
• The College is notified by a customer, 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.

Section 6: Responding to Red Flags

Once potentially fraudulent activity is detected, an employee must act quickly as a rapid appropriate response can protect customers and the College from damages and loss.

• Once potentially fraudulent activity is detected, gather all related documentation and write a description of the situation. Present this information to the designated authority for determination.
• The designated authority will complete additional authentication to determine whether the attempted transaction was fraudulent or authentic.

If a transaction is determined to be fraudulent, appropriate actions must be taken immediately. Actions may include:

• Canceling the transaction;
• Notifying and cooperating with appropriate law enforcement;
• Determining the extent of liability of the College; and
• Notifying the actual customer that fraud has been attempted.

Section 7: Periodic Updates To Plan

• At periodic intervals established in the program, or as required but at least annually, the program will be re-evaluated to determine whether all aspects of the program are up to date and applicable in the current business environment.
• Periodic reviews will include an assessment of which accounts are covered by the program.
• As part of the review, red flags may be revised, replaced or eliminated. Defining new red flags may also be appropriate.
• Actions to take in the event that fraudulent activity is discovered may also require revision to reduce damage to the College and its customers.

Section 8: Program Administration

Involvement of management

• 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.
• The Identity Theft Prevention Program is the responsibility of the governing body. Approval of the initial plan must be appropriately documented and maintained.
• Operational responsibility of the program is delegated to the Controller and the Chief Information Officer.

Staff training

• Staff training shall be conducted for all employees, officials 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 College or its customers.
• The department head for each area is responsible for ensuring identity theft training for all requisite employees and contractors and ensuring their familiarity with this policy.
• To ensure maximum effectiveness, employees may continue to receive additional training as changes to the program are made.

Oversight of service provider arrangements

• It is the responsibility of the College 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.
• 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. It is the responsibility of the Controller and Chief Information Officer to annually review that all providers that maintain college owned covered accounts have theft prevention programs in place.
• Any specific requirements should be specifically addressed in the appropriate contract arrangements.

Definitions*

Identity Theft: An attempt to commit or a committed fraud using the identifying information of another person without that person’s authority.

Identifying Information: Any name or number that may be used alone or in conjunction with other information to identify a specific person. Examples include names, social security numbers and driver’s licenses.

Account: A continuing relationship established by any person with the College to obtain a product or

service from the College for personal, family, household, or business purposes.

Address Discrepancy: A notice sent to a user of a consumer report that informs the user of a substantial difference between the address for the consumer provided by the user in requesting the consumer report and the address or addresses the Consumer Reporting Agency has in the consumer’s file.

Covered Account: An account offered or maintained by the College, acting as a creditor, that is used primarily for personal, family, or household purposes and involves or is designed to permit multiple payments or transactions, or an account for which there is a reasonably foreseeable risk of harm to the account holder or the College from identity theft.

Covered Account Holder: Any person who has a covered account with the College

Credit: The right granted to a person by the College to defer payment of debt or to purchase goods or services and defer payment.

Service Provider: Any third party that provides services to the College. Service providers of the College relating to this program include providers of student and employee health insurance, third-party retirement and other benefits administrators, financial institutions that administer the College’s tuition payment plan programs, governmental and private student loan providers, electronic billing and payment partners, and collections agencies.

Approved by the College Cabinet October 26, 2009

Updated: October 22, 2010; June 8, 2023

* with acknowledgement to Colorado College, Franklin & Marshall College, and Hamilton College