Identity Theft Prevention Program - Red Flag Rules

This policy is to establish an Identity Theft Prevention Program under the Red Flag Rules designed to detect, prevent and mitigate identity theft.

Purpose

Rollins College takes the possibility of identity theft seriously and in full compliance with the Red Flag Rule, has developed and implemented an Identity Theft Program (Program). After consideration of the size of the College’s operations and account systems, and the nature and scope of the College’s activities, the Board of Trustees determined that this Program was appropriate for Rollins College, and therefore approved this Program.

The purpose of this policy is to establish an Identity Theft Prevention Program under the Red Flag Rules designed to detect, prevent and mitigate identity theft in connection with the opening of a covered account or an existing covered account and to provide for continued administration of the Program.

The Program shall include reasonable guidelines and procedures to:

1. Identify relevant red flags for covered accounts it offers or maintains and incorporate those red flags into the program;
2. Detect red flags that have been incorporated into the Program
3. Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
4. Ensure the Program is updated periodically to reflect changes in risks to Students and to the safety and soundness of the creditor from identity theft.

The Federal Trade Commission has issued a final rule (the Red Flag Rule) under the Fair and Accurate Credit Transactions Act of 2003. The Red Flag Rule requires institutions that hold “covered accounts” (accounts for which a person makes repeat payments, see section II B) to develop and implement an identity theft prevention program for new and existing accounts.

The Program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.