Identity Theft Prevention Program

IDENTITY THEFT PREVENTION PROGRAM

POLICY #43

DATE ADOPTED: 1‑26‑09 MINUTE BOOK: 36 PAGE 274

PURPOSE

The purpose of this policy is to comply with the Fair and Accurate Credit Transactions Act and federal regulations at 16 CFR § 681.2 in order to detect, prevent, and mitigate identity theft by identifying and detecting identity theft red flags and responding to such red flags in a manner that will prevent identity theft.

DEFINITIONS

A) Billing Agent Wiregrass Electric Cooperative, Inc.

B) Covered Account An account Houston County offers or maintains for personal, family, or household purposes that invoices or permits multiple payments or transactions (e.g., utility account), and any other account with reasonably foreseeable identity theft risks.

C) Credit The right to defer payment of debt or purchase services and defer payment.

D) Creditor Any person who regularly extends, renews, or continues credit, including Houston County regarding solid waste/sanitation fees.

E) Customer A person with a covered account with Houston County.

F) Identity Theft Fraud committed or attempted using another person’s identifying information without authority.

G) Notice of Address Discrepancy A notice from a consumer reporting agency indicating a substantial difference between the address provided and the address in the agency’s file.

H) Person A natural person, corporation, government entity, trust, estate, partnership, cooperative, or association.

I) Personal Identifying Information (PII) Includes credit card, debit card, bank account, driver’s license information, social security number, mother’s birth name, date of birth, etc.

J) Red Flag A pattern, practice, or specific activity indicating possible identity theft.

K) Service Provider A person providing a service directly to Houston County.

FINDINGS

1. Houston County is a creditor under 16 CFR § 681.2 due to maintaining covered accounts paid in arrears.

2. Covered accounts include solid waste/sanitation fees.

3. No identity theft incidents detected as of adoption of this policy.

4. Opening, restoring, and making payments on covered accounts are potential risk points.

5. Access to PII is limited to employees handling covered accounts; Billing Agent also follows security measures.

6. Identity theft risks include:

Alerts, Notices, and Warnings

• Fraud or active duty alert

• Credit freeze notice

• Consumer report showing unusual activity:

  • Significant increase in inquiries

  • Numerous new credit relationships

  • Material change in credit use

  • Account closed for cause

Suspicious Identification Documents

• Altered or forged

• Photo/description inconsistent with customer

• Information inconsistent with application or records

• Applications appearing altered, forged, destroyed, or reassembled

Suspicious Personal Identifying Information

• Address mismatch

• SSN not issued or listed as deceased

• PII inconsistent with other PII

• PII associated with known fraudulent activity

• SSN duplicated by another customer

• Address/phone number used by unusually large number of applicants

• Failure to provide required PII

Unusual Account Activity

• Unusual activity

• Mail repeatedly returned undeliverable

• Customer not receiving statements

• Unauthorized charges or transactions

Notices from Customers or Authorities

Reports of possible identity theft related to covered accounts.

DETECTION, PREVENTION, AND MITIGATION

Detection

Customers must provide:

• Full Name

• Date of Birth

• Address

• Social Security Number or Taxpayer ID

• For non‑US citizens: passport, alien ID, or other government ID with photo and nationality

Prevention and Mitigation

If identity theft is detected, Houston County or the Billing Agent may:

• Monitor the account

• Contact the customer

• Reopen account with new number

• Close existing account

• Cease collection efforts

• Determine no response is warranted

Billing Agent will ensure privacy and control of online credit card payments.

Billing Agent will maintain its own Red Flags Policy.

Houston County Commission will annually review and update the program considering:

1. Experience with identity theft

2. Updated identity theft methods

3. Updated detection/prevention methods

4. Updated account types

5. Updated service provider arrangements

TREATMENT OF ADDRESS DISCREPANCIES

When receiving a notice of address discrepancy, employees may:

1. Compare consumer report information with:

   • Identity verification information

   • County or Billing Agent records

   • Reliable third‑party sources

OR

1. Verify the information directly with the customer.

FURNISHING CONSUMER’S ADDRESS TO REPORTING AGENCY

If the address is reasonably confirmed:

• County/Billing Agent must provide the address to the reporting agency

• Only if: a) Reasonable belief the report relates to the consumer b) A continuing relationship is established c) County/Billing Agent regularly provides information to that agency

METHODS OF CONFIRMING ADDRESSES

Employees may confirm addresses by:

1. Verifying with the consumer

2. Reviewing County/Billing Agent records

3. Using third‑party sources

4. Using other reasonable methods

PROGRAM ADMINISTRATION AND OVERSIGHT

• The Chief Administrative Officer (CAO) oversees the program.

• CAO reviews compliance reports and recommends changes.

• CAO reports annually to the Commission (due by September 30).

• Report includes:

  1. Program effectiveness

  2. Service provider arrangements

  3. Significant identity theft incidents

  4. Recommended changes

CAO provides training to employees involved in covered accounts.

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