Policies & Procedures Manual - Elizabeth City State University

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400.3.1.21Adopted: 04/23/09Page 2 of 7o Employer or taxpayer identification numbero Individual identification numbero Computer’s Internet Protocol addresso Bank or other financial account routing codeD. “Identity Theft” means a fraud committed or attempted using the Identifying Information of anotherperson without authority.E. “Program Administrator” means the individual designated with primary responsibility foroversight of the Program.F. “Red Flag” means a pattern, practice, alert or specific activity that indicates the possible existence ofIdentity Theft.G. “Service Provider” means a person or entity that provides a service directly to the University.3. Identification of Red FlagsIn order to identify relevant Red Flags, the University considers the types of Covered Accounts it offers ormaintains, the methods it provides to open its Covered Accounts, the methods it provides to access itsCovered Accounts, and its previous experiences with Identity Theft.Red Flags may be detected while implementing existing account opening and servicing procedures such as:individual identification, caller authentication, third party authorization, and address changes.The University identifies the following Red Flags in each of the listed categories:A. Notifications and Warnings from Consumer Reporting Agencieso Report of fraud accompanying a credit report;o Notice or report from a credit agency of a credit freeze on an applicant;o Notice or report from a credit agency of an active duty alert for an applicant;o Receipt of a notice of address discrepancy in response to a credit report request; ando Indication from a credit report of activity that is inconsistent with an applicant’s usual patternor activity.B. Suspicious Documentso Identification document or card that appears to be forged, altered or inauthentic;o Identification document or card on which a person’s photograph or physical description is notconsistent with the person presenting the document;o Other document with information that is not consistent with existing individual information;ando Application for service that appears to have been altered or forged.
400.3.1.21Adopted: 04/23/09Page 3 of 7C. Suspicious Personal Identifying Informationo Identifying Information presented that is inconsistent with other information the individualprovides (example: inconsistent birth dates);o Identifying Information presented that is inconsistent with other sources of information(example: an address not matching an address on a loan application);o Identifying Information presented that is the same as information shown on other applicationsthat were found to be fraudulent;o Identifying Information presented that is consistent with fraudulent activity (examples: aninvalid phone number or fictitious billing address);o Social security number presented that is the same as one given by another individual;o An address or phone number presented that is the same as that of another person;o A person fails to provide complete personal Identifying Information on an application whenreminded to do so; ando A person’s Identifying Information is not consistent with the information that is on file for theindividual.D. Suspicious Covered Account Activityo Change of address for an account followed by a request to change the individual’s name;o Payments stop on an otherwise consistently up-to-date account;o Account used in a way that is not consistent with prior use;o Mail sent to the individual is repeatedly returned as undeliverable;o Notice to the University that an individual is not receiving mail sent by the University;o Notice to the University that an account has unauthorized activity;o Breach in the University’s computer system security; ando Unauthorized access to or use of individual account information.E. Alerts from Otherso Notice to the University from an individual, Identity Theft victim, law enforcement or otherperson that the University has opened or is maintaining a fraudulent account for a personengaged in Identity Theft.4. Detection of Red FlagsA. Student EnrollmentIn order to detect any of the Red Flags identified above associated with the enrollment of a student,University personnel shall take the following steps to obtain and verify the identity of the person openingthe account:o Require certain Identifying Information such as name, date of birth, academic records, homeaddress or other identification; and
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400.1.12Rare ProcedureThis procedur
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400.1.22Notice of Award After contr
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400.1.31First Priority to Other Sta
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400.1.45final debiting of your univ
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