I. Program Adoption
The University of Arkansas System Board of Trustees adopted an Identity Theft Prevention Program (“Program”) in compliance with Part 681 of the Code of Federal Regulations implementing Sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003 and pursuant to the Federal Trade Commission’s (“FTC”) Red Flags Rule (“Rule”). The purpose of this program is to establish processes at the University of Arkansas campuses to:
- Identify relevant red flags for new and existing covered accounts and incorporate those red flags into the program.
- Detect red flags that have been incorporated into the program.
- Respond appropriately to any red flags that are detected to prevent and mitigate identity theft.
- Ensure the program is updated periodically to reflect changes in risks to students or to the safety and soundness of the student from identity theft.
Each campus is responsible for implementing a plan to:
- Identify covered accounts.
- Identify relevant red flags.
- Establish policies and procedures to detect red flags and respond appropriately.
- Establish policies and procedures to ensure appropriate and effective oversight of service providers.
- Provide training to the appropriate staff in the detection of red flags and responsive steps required when a red flag is detected.
- Report to the program administrator on incidents of identity theft, the effectiveness of the program, campus compliance with the program, and other relevant data.
- Designate a campus administrator who is responsible for administering and implementing the program at the campus level.
Identity Theft. A fraud committed or attempted using the identifying information of another person without authority.
Red Flag. A pattern, practice, or specific activity that indicates the possible existence of identity theft.
Covered Account. Any account the university offers or maintains that is designed to permit multiple payments or transactions or one for which there is a foreseeable risk of identity theft.
Program Administrator. The associate vice chancellor for finance is designated with primary responsibility for oversight of the program.
Identifying Information. Any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including: 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.
III. Identification of Covered Accounts
The university has determined that covered accounts are established and maintained that fall under the requirements of FTC Rule 681.1, 681.2 and 681.3 describes as follows:
- Utilization of reports from consumer reporting agencies for credit or background checks for loan issuance or collection purposes. (681.1)
- Utilization of reports from consumer reporting agencies for credit or background checks of new hire applicants or employees in positions identified as requiring credit or background checks. (681.1)
- Establishment of credit accounts for students such as deferred payment plans for tuition and fees, Perkins loans, and emergency loans. (681.2)
- Establishment of debit/credit deposit accounts for students, faculty, and staff. (681.3)
IV. Identification of Red Flags
In order to identify relevant red flags, the university considers 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 identifies the following red flags in each of the listed categories:
Notifications and Warnings from Credit Reporting Agencies
- Report of fraud accompanying a credit report.
- Notice or report from a credit agency of a credit freeze on an applicant.
- Notice or report from a credit agency of an active duty alert for an applicant.
- Receipt of a notice of address discrepancy in response to a credit report request.
- Indication from a credit report of activity that is inconsistent with an applicant’s usual pattern or activity.
- Identification document or card that appears to be forged, altered, or inauthentic.
- Identification document or card on which a person’s photograph or physical description is not consistent with the person presenting the document.
- Other document with information that is not consistent with existing student information.
- Application for service that appears to have been altered or forged.
Suspicious Personal Identifying Information
- Identifying information presented that is inconsistent with other information the student provides (example: inconsistent birth dates).
- Identifying information presented that is inconsistent with other sources of information (for instance, an address not matching an address on a loan application).
- Identifying information presented that is the same as information shown on other applications that were found to be fraudulent.
- Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address).
- Social security number presented that is the same as one given by another student.
- An address or phone number presented that is the same as that of another person.
- A person fails to provide complete personal identifying information on an application when reminded to do so.
- A person’s identifying information is not consistent with the information that is on file for the student.
Suspicious Student Account Activity or Unusual Use of Account
- Change of address for an account followed by a request to change the student’s name.
- Payments stop on an otherwise consistently up-to-date account.
- Account used in a way that is not consistent with prior use.
- Mail sent to the student is repeatedly returned as undeliverable.
- Notice to the university that a student is not receiving mail sent by the university.
- Notice to the university that an account has unauthorized activity.
- Breach in the university’s computer system security.
- Unauthorized access to or use of student account information.
Alerts from Others
- Notice to the university from a student, identity theft victim, law enforcement, or other person that the university has opened or is maintaining a fraudulent account for a person engaged in identity theft.
V. Detecting Red Flags
In order to detect any of the red flags identified above associated with the enrollment of a student, university personnel will take the following steps to obtain and verify the identity of the person opening the account:
- Require certain identifying information such as name, date of birth, academic records, home address, or other identification.
- Verify the student’s identity at time of issuance of student identification card (review of driver’s license or other government-issued photo identification).
In order to detect any of the red flags identified above for an existing student account, university personnel will take the following steps to monitor transactions on an account:
- Verify the identification of students if they request information (in person, via telephone, via facsimile, via email).
- Verify the validity of requests to change billing addresses by mail or email and provide the student a reasonable means of promptly reporting incorrect billing address changes.
- Verify changes in banking information given for billing and payment purposes.
Consumer (“Credit”) Report Requests
In order to detect any of the red flags identified in this training for employment or as part of any university sponsored degree program for which a credit or background report is sought, university personnel will take the following steps to assist in identifying address discrepancies:
- Prior to requesting a background or credit check, university personnel must require written documentation, from the applicant, that the address and information provided is correct at the time the consumer report is being requested.
- If an address discrepancy is found in the completed consumer report, university personnel must verify the address, with the applicant, to insure the consumer report actually pertains to the applicant for which the report was requested. Any unresolved address discrepancies should be reported to the consumer reporting agency.
VI. PREVENTING AND MITIGATING IDENTITY THEFT
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 fed flag:
Prevent and Mitigate
- Notify their immediate supervisor, who should then notify the department head or director of the department to determine if additional steps are needed.
- The account holder should only be contacted upon approval from the department head, director, or associate vice chancellor for finance.
- Continue to monitor a covered account for evidence of identity theft.
- The department head or director of the department should notify the associate vice chancellor for finance of the possible identity theft, for determination of the appropriate step(s) to take.
- All instances of possible identity theft should be kept strictly confidential.
The department head or director may take one or more of the following steps, depending on the degree of risk posed by the red flag:
- Contact the student or applicant (for which a credit report was run).
- Change any passwords or other security devices that permit access to covered accounts.
- Not open a new covered account.
- Provide the student with a new student identification number.
- Notify law enforcement.
- File or assist in filing a Suspicious Activities Report (“SAR”).
- Determine that no response is warranted under the particular circumstances.
Protect Student Identifying Information
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 student identifying information:
- Ensure that its website is secure or provide clear notice that the website is not secure.
- Ensure complete and secure destruction of paper documents and computer files containing student account information when a decision has been made to no longer maintain such information.
- Ensure that office computers with access to covered account information are password protected.
- Avoid use of social security numbers (see UA Little Rock’s Information Technology Acceptable Use Policy);
- Ensure computer virus protection is up to date.
- Require and keep only the kinds of student information that are necessary for university purposes.
VII. PROGRAM ADMINISTRATION
Responsibility for developing, implementing and updating this program lies with an identity theft committee (“committee”) for the university. The committee is headed by the associate vice chancellor for finance. Two or more other individuals appointed by the associate vice chancellor for finance comprise the remainder of the committee membership. The associate vice chancellor for finance 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.
Staff Training and Reports
University staff responsible for implementing the program shall be trained either by or under the direction of the associate vice chancellor for finance 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 associate vice chancellor for finance 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 associate vice chancellor for finance, university staff responsible for development, implementation, and administration of the program shall report to him or her 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, significant incidents involving identity theft and management’s response, and recommendations for changes to the program.
Service Provider Arrangements
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 reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft.
- Require, by contract, that service providers have such policies and procedures in place.
- Require, by contract, that service providers review the university’s program and report any red flags to the associate vice chancellor for finance or the university employee with primary oversight of the service provider relationship.
Non-Disclosure of Specific Practices
For the effectiveness of this Identity Theft Prevention Program, knowledge about specific fed flag identification, detection, mitigation, and prevention practices may need to be limited to the committee who developed 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 considered “confidential” and should not be shared with other university employees or the public. The associate vice chancellor for finance 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.
The committee will periodically review and update this program to reflect changes in risks to students and the soundness of the university from identity theft. In doing so, the committee will consider the university’s experiences with identity theft situations, changes in identity theft methods, changes in identity theft detection and prevention methods, and changes in the university’s business arrangements with other entities. After considering these factors, the associate vice chancellor for finance will determine whether changes to the program, including the listing of red flags, are warranted. If warranted, the committee will update the program.