Number: 145

Subject:  AMBERTON UNIVERSITY IDENTITY THEFT PREVENTION PROGRAM

     Amberton University has developed an Identity Theft Prevention Program (Program) pursuant to the Federal Trade Commission’s Red Flags Rule, which implements Section 114 of the “Fair and Accurate Credit Transactions Act of 2003.”  The Vice President for Administrative Services coordinates the Program as authorized by the Office of the President.  Coordination of the Program includes training of all University personnel who, in the course of their job responsibilities, are in positions where “Red Flags” indicating possible identity theft are likely to be identified.  “Red Flags” are defined as patterns, practices, or specific activities that indicate the possible existence of identity theft.

     The Identity Theft Prevention Program document is on file in the Business Services Office.  The Program contains reasonable policies and procedures to:

1. Identify relevant Red Flags for new and existing academic records, financial accounts, and personnel files and incorporate these 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.

This regulation is coordinated with Policies and Regulations #140 (Amberton University Information Security Program), which addresses the “safeguarding” all records containing nonpublic personal information on an employee or student.