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3. Change any passwords or other security devices that permit access to accounts; <br /> 4. Not open a new account; <br /> 5. Close an existing account; <br /> 6. Reopen an account with a new number; <br /> 7. Notify the Program Administrator for determination of the appropriate step(s)to <br /> take; <br /> 8. Notify law enforcement; or <br /> 9. Determine that no response is warranted under the particular circumstances. <br /> P <br /> Protect Customer Identifying Information <br /> In order to further prevent the likelihood of Identity Theft occurring with respect to <br /> Utility accounts,the Utility will take the following steps with respect to its internal <br /> operating procedures to protect customer identifying information: <br /> 1. Ensure that its website is secure or provide clear notice that the website is not <br /> secure; <br /> 2. Ensure complete and secure destruction of paper documents and computer <br /> files containing customer information; <br /> 3. Ensure that office computers are password protected and that computer <br /> screens lock after a set period of time; <br /> 4. Keep offices clear of papers containing customer information; <br /> 5. Ensure computer virus protection is up to date; and <br /> 6. Require and keep only the kids of customer information that are necessary for <br /> utility purposes; <br /> 7. Have all staff with access to protected information sign off on a customer <br /> privacy understanding statement which states that a violation of customers; <br /> privacy results in consequences up to, and including,possible termination. <br /> 6.0 Program Updates <br /> A. The Program Administrator will periodically review and update this Program to <br /> reflect changes in risks to customers and the soundness of the Utility from Identity <br /> Theft. In doing so, the Program Administrator will consider the Utility's experiences <br /> with Identity Theft situations, changes in Identity Theft methods, changes in Identity <br /> Theft detection and prevention methods, and changes in the Utility's business <br /> arrangements with other entities. After considering these factors, the Program <br /> Administrator will determine whether changes to the program, including the listing of <br /> Red Flags, are warranted. If warranted,the Program Administrator will update the <br /> Program and present the Utility commission with his or her recommended changes <br /> and the Utility Commission will make a determination of whether to accept, modify, <br /> or reject those changes to the Program. <br /> 7.0 Program Administration <br /> A. Oversight <br /> 115 <br />