目的
The purpose of this policy is to establish a Red Flags Rule 防止身份盗窃 Program 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. 该计划应包括合理的政策和程序，以便:
• Identify relevant Red Flags for covered accounts the University offers or maintains and incorporate those Red Flags into its Program;
•发现已纳入大学计划的危险信号;
•对检测到的任何危险信号作出适当反应，以防止和减轻身份盗窃;
• Ensure the Program is updated periodically to reflect changes in risks to students and borrowers and to the safety and soundness of the University from identity theft; and
•该计划应, 适当的, 结合现有的政策和程序来控制合理可预见的风险.
现行政策及措施
学院有政策确保遵守格雷姆-里奇-比利利法案(GLB)。, 家庭教育权利和隐私法(FERPA), 系统和应用安全, and internal control procedures which provide an environment where identity theft opportunities are mitigated. 为确保学生及借阅人记录的私隐及机密性，有关记录会受到妥善保管.
此外，大学坚持以下做法:
•所有纸质文件在不使用时都要锁在办公室和/或文件柜里.
• Access to confidential information is limited to only those employees who need access in order to properly perform the duties for which they were hired.
• Employees with access to confidential information understand that this is confidential business information and is not to be discussed with anyone who does not “need to know.”
定义
• Identify theft means fraud committed or attempted using the identifying information of another person without authority.
• Account means a continuing relationship established by a person with the creditor to obtain a product or service for personal purposes. 帐户包括延期付款的信贷延期.
• Covered account means an account that a creditor offers or maintains primarily for personal purposes that involves or is designed to permit multiple payments or transactions.
•红旗意味着一种模式, 表明可能存在身份盗窃的行为或具体活动.
覆盖账户
•学院参与联邦珀金斯贷款计划
•学院提供并建立学生付款计划
识别相关危险信号
• The photograph or physical description on the identification is not consistent with the appearance of the student or borrower presenting the identification.
•提供的SSN与其他学生或借款人提交的SSN相同.
• The address or telephone number provided is the same as or similar to the account number or telephone number submitted by an unusually large number of other students or borrowers.
• The person opening the covered account or the student or borrower fails to provide all required personal identifying information on an application or in response to notification that the application is complete.
• A covered account is used in a manner that is not consistent with established patterns of activity on the account – nonpayment when there is no history of late or missed payments.
• The College is notified of unauthorized charges or transactions in connection with a student or borrower’s covered account.
•学生或借款人通知学院, 身份盗窃的受害者, 执法机关, 或者任何其他人为从事身份盗窃的人开设了欺诈账户的人.
侦测红旗活动
承保账户的开立方式如下:
联邦珀金斯贷款计划
•珀金斯借款人使用电子签名签署本票, 它要求每个借款者都有一个唯一的密码.
• Perkins borrowers can allow a third party to have access to his/her account information by completing the FERPA form in the electronic exit interview process. 如果没有人被列出, a third party will not have access to any account information without the borrower’s written permission. The borrower can log onto the exit site at any time to update this information if he/she decides that it would be beneficial for another party to have access to account information.
学生付款计划
学生必须打电话, e-mail or come into the Director of Student Account’s Office to request their account be placed on a tuition payment plan.
应对危险信号
The Program shall provide for appropriate responses to detected red flags to prevent and mitigate identity theft. 对有关危险信号的适当回应如下:
•联系学生或借款人;
•更改任何密码, 安全码, 或允许访问受保护帐户的其他安全设备;
•用新账号重新开通已覆盖的账户;
•关闭现有的承保账户;
•不试图在承保账户上进行催收;
• Notifying law enforcement; and/or
•确定在特定情况下无需作出回应.
更新程序
学院将在每年12月更新课程, to reflect changes in risks to students or borrowers or to the safety and soundness of the University from identity theft, 基于以下因素:
•大学与身份盗窃的经验;
•身份盗窃方法的变化;
• Changes in methods to detect, prevent, and mitigate identity theft; and
•大学提供或维护的账户类型发生变化.
监督服务提供者安排
The College shall take steps to ensure that the activity of a service provider is conducted in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft whenever the University engages a service provider to perform an activity in connection with one or more covered accounts.
目前，该大学使用校园合作伙伴来管理珀金斯贷款计划. Students contact Campus Partners directly through its website or by telephone and provide personal identifying information to be matched to the records that the University has provided to Campus Partners.
