PERIODIC UPDATES TO PLAN
a: At periodic intervals established in the program, or as required, the program will be re- evaluated to determine whether all aspects of the program are up-to-date and applicable in the current college environment.
b: Periodic reviews will include an assessment of which accounts are covered by the program.
c: As part of the review, red flags may be revised, replaced or eliminated. Defining new red flags may also be appropriate.
PROGRAM ADMINISTRATION a: Involvement of the administration
1. The Identity Theft Prevention Program is the responsibility of the Board of Trustees. Approval of the initial plan will be appropriately documented and maintained.
2. Operational responsibility of the program is delegated to the Vice President for Finance and Administration, who may also delegate to appropriate personnel.
b: Staff training
1. Staff training will 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 involve a risk to the college or its customers.
2. These employees will receive annual training in all elements of this policy; they may continue to receive additional training as changes to the program are made.
c: Oversight of service provider arrangements
1. The college will 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. Each employee working with service providers is responsible for informing those providers of the requirements of this policy.
2. 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.
3. Any specific requirements should be specifically addressed in the appropriate contract arrangements.
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