Identity Theft Prevention Program
Introduction
The New School (the “University”) has developed this Identity Theft Prevention Program (the “Program”) pursuant to the Federal Trade Commission’s “Red Flags Rule,” which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. The Program is designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account, or an existing covered account offered or maintained by the University. This Program establishes procedures to:
Identify relevant Red Flags for Covered Accounts it offers or maintains and incorporate those Red Flags into the Program;
Detect and record Red Flags that have been incorporated into the Program;
Respond appropriately to any Red Flag that has been detected to prevent and mitigate identify theft; and
- Ensure the Program is updated periodically to reflect changes in identity theft risks to students and employees or to the safety and soundness of the University in its role as creditor.
The Program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.
Definitions
Covered Accounts: (i) an account the University offers or maintains primarily for personal, family or household purposes, that involves or is designed to permit multiple payments or transactions; or (ii) any other account that the University offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the University from identity theft.
The University has identified the following Covered Accounts:
- University Administered Covered Accounts – Students:
- Federal Perkins Loan Program
- Deferred Tuition Payments
- Student Accounts
- Monthly Payment Plans
- University Administered Covered Accounts – Employees:
- Mortgages
- Service Provider Covered Accounts:
- Campus Partners – Collection of Perkins and Institutional Loans
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.
Identification of 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:
A. 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 a customer or applicant;
Notice or report from a credit agency of an active duty alert for an applicant; and
- Indication from a credit report of activity that is inconsistent with a customer’s usual pattern or activity.
B. Suspicious Documents
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 customer information (such as if a person’s signature on a check appears forged); and
- Application for service that appears to have been altered or forged.
C. Suspicious Personal Identifying Information
Identifying information presented that is inconsistent with other information the customer provides (example: inconsistent birth dates);
Identifying information presented that is inconsistent with other sources of information (example: an address not matching an address on a credit report);
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 (example: an invalid phone number or fictitious billing address);
Social security number presented that is the same as one given by another customer;
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; and
- A person’s identifying information is not consistent with the information that is on file for the customer.
D. Suspicious Requests
A request related to transactions involving a Covered Account is made from a non-University issued email account; and
- A request is made to mail something to an address not listed on file.
E. Suspicious Account Activity or Unusual Use of Account
Change of address for an account followed by a request to change the account holder's name;
Payments stop on an otherwise consistently up-to-date account;
Account used in a way that is not consistent with prior use (example: very high activity);
Mail sent to the account holder is repeatedly returned as undeliverable;
Notice to the University that a customer 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; and
- Unauthorized access to or use of customer account information.
F. Alerts from Others
Notice to the University from a customer, identity theft victim, law enforcement or other person regarding possible identify theft in connection with Covered Accounts.
Detection of Red Flags
New Accounts
In order to detect any of the Red Flags identified above associated with the opening of a new account, 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, residential or business address, driver's license or other identification;
Verify the customer's identity (for instance, review a driver's license or other identification card);
- Independently contact the customer.
Existing Accounts
In order to detect any of the Red Flags identified above for an existing account, University personnel will take the following steps to monitor transactions with an account:
Verify the identification of customers if they request information (in person, via telephone, via facsimile, via email);
Verify the validity of requests to change billing addresses; and
Verify changes in banking information given for billing and payment purposes.
Responding to Red Flags and Mitigating Identity Theft
In the event University personnel detect any identified Red Flags, such personnel shall take all appropriate steps to respond and mitigate identity theft depending on the nature and degree of risk posed by the Red Flag, including but not limited to the following examples:
Deny access to the Covered Account until other information is available to eliminate the Red Flag;
Continue to monitor a Covered Account for evidence of identity theft;
Contact the customer;
Change any appropriate passwords, security codes or other security devices that permit access to a Covered Account;
Do not open a new account;
Reopen a Covered Account with a new number;
Close an existing Covered Account;
Notify the University’s Security Department and/or law enforcement;
- Determine that no response is warranted under the particular circumstances.
Service Provider Arrangements
In the event the University engages a service provider to perform an activity in connection with one or more accounts, the University will take appropriate 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. Such steps may include the following:
Review a copy of the service provider’s identity theft policies and procedures;
Require, by contract, that service providers have such policies and procedures in place; and
- Require, by contract, that service providers review the University’s Program and report any Red Flags to the Program Administrator.
Program Administration and Maintenance
The Vice President and Treasurer shall be designated to serve as the Program’s Administrator. The Program Administrator is responsible for developing, implementing and updating the Program. The Program Administrator will be responsible for Program administration, ensuring appropriate training of University staff on the Program, for reviewing any staff reports regarding the detection of Red Flags and the steps for identifying, 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.
The Program will be periodically reviewed and updated to reflect changes in identity theft risks and technological changes. The Program Administrator will consider the University’s experiences with identity theft; changes in identity theft methods; changes in identity theft detection, mitigation and prevention methods; changes in types of accounts the University maintains; changes in the University’s business arrangements with other entities; and any changes in legal requirements in the area of identity theft.
After considering these factors, the Program Administrator will determine whether changes to the Program, including the listing of Red Flags, are warranted. If warranted, the Program will be updated.
Staff Training
University staff responsible for implementing the Program shall be trained either by or under the direction of the Program Administrator in the detection of Red Flags and responsive steps to be taken when a Red Flag is detected.
This Program has been developed by the following offices at the University: General Counsel, Finance and Business, Information Technology and Enrollment Management.