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Information Security Management and Compliance
Division of Administratin and Finance

Identity Theft Red Flag and Security Incident Reporting Procedure

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1. Purpose

   The purpose of the Identify Theft Red Flag and Security Incident Reporting Procedure is to provide information to assist individuals in 1) detecting, preventing, and mitigating identity theft in connection with the opening of a “covered account” or any existing “covered account” or who believe that a security incident has occurred and 2) reporting a security incident.

2. Background

   Security Incident
   Existing California law requires that any organization that owns computerized data that includes personal information shall disclosure any breach of security of the system following discovery or notification of the breach in the security of the system to any resident of California whose unencrypted personal information was, or is reasonably believed to have been, acquired by an unauthorized person.

   Red Flag Rules
   In 2003, the U.S. Congress enacted the Fair and Accurate Credit Transaction Act of 2003 (FACT Act) which required the Federal Trade Commission (FTC) to issue regulations requiring “creditors” to adopt policies and procedures to prevent identify theft.

   In 2007, the Federal Trade Commission (FTC) issued a regulation known as the Red Flag Rule. The rule requires “financial institutions” and “creditors” holding “covered accounts” to develop and implement a written identity theft prevention program designed to identify, detect and respond to “Red Flags.”

3. Definitions

   Covered Account
   A covered account is a consumer account designed to permit multiple payments or transactions.  These are accounts where payments are deferred and made by a borrower periodically over time such as a tuition or fee installment payment plan.

   Creditor
   A creditor is a person or entity that regularly extends, renews, or continues credit and any person or entity that regularly arranges for the extension, renewal, or continuation of credit. Examples of activities that indicate a college or university is a “creditor” are:

   • Participation in the Federal Perkins Loan program;
   • Participation as a school lender in the Federal Family Education Loan Program;
   • Offering institutional loans to students, faculty or staff;
   • Offering a plan for payment of tuition or fees throughout the semester, rather than requiring full payment at the beginning of the semester

   Personal Information
   Specific items of personal information identified in CA Civil Code Sections 1798.29 and 1798.3. This information includes an individual’s first name or first initial and his or her last name in combination with any one or more of the following data elements, when either the name or the data elements are not encrypted or redacted: Social Security Number, driver’s license/California identification card number, health insurance information, medical information, or financial account number such as credit card number, in combination with any required security code, access code, or password that would permit access to an individual’s financial account.

   Red Flag
   A red flag is a pattern, practice or specific activity that indicates the possible existence of identity theft.

   Security Incident
   A collection of related activities or events which provide evidence that personal information could have been acquired by an unauthorized person.

4. IDENTIFICATION OF RED FLAGS

   Broad categories of “Red Flags” include the following:

   • Alerts – alerts, notifications, or warnings from a consumer reporting agency including fraud alerts, credit freezes, or official notice of address discrepancies.
   • Suspicious Documents – such as those appearing to be forged or altered, or where the photo ID does not resemble its owner, or an application which appears to have been cut up, re-assembled and photocopied.
   • Suspicious Personal Identifying Information – such as discrepancies in address, Social Security Number, or other information on file; an address that is a mail-drop, a prison, or is invalid; a phone number that is likely to be a pager or answering service; personal information of others already on file; and/or failure to provide all required information.
   • Unusual Use or Suspicious Account Activity –such as material changes in payment patterns, notification that the account holder is not receiving mailed statement, or that the account has unauthorized charges;
   • Notice from Others Indicating Possible Identify Theft–such as the institution receiving notice from a victim of identity theft, law enforcement, or another account holder reports that a fraudulent account was opened.

5. DETECTION OF RED FLAGS

   Detection of Red Flags in connection with the opening of covered accounts as well as existing covered accounts can be made through such methods as:

   • Obtaining and verifying identity;
   • Authenticating customers;
   • Monitoring transactions

   A data security incident that results in unauthorized access to a customer’s account record or a notice that a customer has provided information related to a covered account to someone fraudulently claiming to represent the University or to a fraudulent web site may heighten the risk of identity theft and should be considered Red Flags.

6. RESPONSE TO RED FLAGS

   The detection of a Red Flag by an employee shall be reported to the Director, Information Security Management and Compliance and their appropriate administrator. Based on the type of red flag, the appropriate administrator and the Director, Information Security Management and Compliance together with the employee will determine the appropriate response.

7. SECURITY INCIDENT REPORTING

   An employee who believes that a security incident has occurred, shall immediately notify their appropriate administrator and the Director, Information Security Management and Compliance. After normal business hours, notification shall be made to the University police (562) 985-4101.

8. SERVICE PROVIDERS

   The University remains responsible for compliance with the Red Flag Rules even if it outsources operations to a third party service provider. The written agreement between the University and the third party service provider shall require the th ird party to have reasonable policies and procedures designed to detect relevant Red Flags that may arise in the performance of their service provider’s activities. The written agreement must also indicate whether the service provider is responsible for notifying only the University of the detection of a Red Flag or if the service provider is responsible for implementing appropriate steps to prevent or mitigated identify theft.

9. TRAINING

   All employees who process any information related to a covered account shall receive training following appointment on the procedures outlined in this document. Refresher training may be provided annually.