Approved by: President and the Board of Trustees
History: Issued             -- May 8, 2009
Revised           -- October 11, 2018
Additional History: Approved by the Board of Trustees on Sept. 29, 2009
Last Reviewed -- October 11, 2018
Related Policies: Information Security and Assurance Policy; Student Records Policy;
Additional References: Fair and Accurate Credit Transactions Act; Consumer Personal Information Security Breach Act (DC); CUA Red Flag Action Report Form
Responsible Official: Chief Information Officer tel. (202) 319-5373

 

I. Introduction

 

The University recognizes some of its activities are subject to the provisions of the Federal Fair and Accurate Credit Transactions Act (FACTA) and the Federal Trade Commission's Red Flag Rules. The purpose of this policy is to provide information to assist individuals in the detection, prevention, and mitigation of Identity Theft in connection with the opening of a Covered Account or any existing Covered Account. This policy also provides guidance to employees who believe that a security incident may have occurred and with the reporting of a security incident.

Under the Red Flag rules, the University is required to establish an "Identity Theft Program" with reasonable policies and procedures to detect, identify, and mitigate identity theft in its covered accounts. These "Red Flags" are inconsistencies in specific financial transactions which should indicate further investigation when noticed. The University must incorporate relevant Red Flags into a Program to enable the University to detect and respond to potential Identity Theft.

II. Definitions

 

Pursuant to the Red Flag regulations at 16 C. F. R. § 681.2, the following definitions shall apply to this Program:

A. Red Flag. A suspicious pattern or practice, or specific activity that indicates the possible existence of Identity Theft.

B. Identity Theft. A fraud committed using the identifying information of another person.

C. Covered Accounts

  1. Any account the University offers or maintains primarily for personal, family or household purposes, that involves multiple payments or transactions.
  2. Any other account 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.

D. Credit. The right granted by a creditor to a debtor to defer payment of debt or to incur debt and defer its payment or to purchase property or services and defer payment.

E. Creditor. An entity that regularly extends, renews, or continues credit.

F. Customer. Any person with a covered account with a creditor.

G. Identifying Information. Any name or number that may be used, alone or in conjunction with any other information, to identify a specific person including:
  • Name
  • Address
  • Telephone number
  • Social Security Number
  • Date of birth
  • Government issued driver's license, identification number, or alien registration number
  • Government passport number
  • Employer or taxpayer identification number
  • Unique electronic identification number
  • Computer's Internet Protocol (IP) address or routing code

III. Identification of Red Flags

 

In order to identify relevant Red Flags, the University considers the types of accounts that it offers and maintains, the methods it provides to open its accounts, the methods it provides to access its accounts, and its previous experiences with Identity Theft. The following are typical or frequent trouble spots of which employees should be aware and for which employees should diligently monitor and take action:

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 (e.g. 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 (e.g. inconsistent birth dates)
  • Identifying information presented that is inconsistent with other sources of information (e.g. 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 (e.g. 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 (however, by law, Social Security Numbers must not be required); and
  • A person's identifying information is not consistent with the information that is on file for the customer.

D. 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 (e.g. 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.

E. Alerts from Others

 

Notice to the University from a customer, Identity Theft victim, law enforcement or other person that the University has opened or is maintaining a fraudulent account for a person engaged in Identity Theft.

IV. 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:

A. 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.

B. 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.

C. Social Security Numbers

 

In all cases, special care should be taken to avoid asking for a Social Security Number unless its collection has been authorized by the Information Security Officer.

D. Special Cases

 

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.

V. Responding to Red Flags

 

In the event University employees detect any identified Red Flags, notify the Information Security Office at TS-Security@cua.edu of the event so that they can review electronic accounts associated with the Red Flag Event for concommitant events.

The University 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:

  • Continue to monitor an account for evidence of Identity Theft;
  • Contact the customer;
  • Change any passwords or other security devices that permit access to accounts;
  • Not open a new account;
  • Close an existing account;
  • Reopen an account with a new number;
  • Determine that no response is warranted under the particular circumstances.

If you have questions concerning the appropriate steps to take, these questions should be directed to the appropriate supervisor or the Information Security Officer (TS-Security@cua.edu). Employees should not contact Law Enforcement agencies directly, but should consult with their supervisor or the Information Security Officer, who will consult with the Office of General Counsel.

VI. Contractual Agreements

 

In the event the University engages a service provider to perform an activity in connection with one or more accounts, the University will take the following 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:

  • 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 relevant University official.

VII. Training


University employees responsible for implementing the Program shall be trained under the direction of the Information Security Officer in the detection of Red Flags, and the responsive steps to be taken when a Red Flag is detected.

VIII. Security Incident Reporting

 

An employee who believes that a security incident has occurred shall immediately notify their appropriate administrator and the Information Security Officer (TS-Security@cua.edu).