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.^~/ <br />Elk River <br />Municipal Utilities <br />13069 Orono Parkway • P.O. Box 430 <br />Elk River, MN 55330-0430 <br />October 10, 2008 <br />To: Ell: River Municipal Utilities commission <br />Jerry Takle <br />Jim Tralle <br />John Dietz <br />From: Theresa Slominski <br />Subject: Red Flag/Identity Theft Prevention Policy <br />Phone: 763.441.2020 <br />Fax: 763.441.8099 <br />fay November i st, the Federal Trade Commission (FTC) "Red Flag" regulations are <br />requirint, all banks and other "creditors" to design and approve their own tailored plans <br />for preventing th:r ~ uston.~ers' information fi~i~raa being stolen or used illegally. Under <br />these regulations,. tl,;.. form "~.rf~ditor" encompasses all utilities, inchiding municipal <br />z~til:tics, because t;7e°; provide service ai~ead of payaYat~r;t. "IZod Fiat g" is the term used in <br />the regulatic:>ns t:c? re~:~r to v~aa-aairg signs that a customer's personal information has been <br />compa orr~~.ist:d~. <br />MMUA provided a model template to utilities as guidance for adopting their own plan. <br />The template was reviewed and modified to reflect ERMU current practices and policies. <br />In the last few years, with the adoption of collecting social security numbers and other <br />identification, adopting a deposit policy, and utilizing the resource of Online Utility <br />Exchange, we have many of these "Red Flag" issues addressed. We have passwords, <br />computer timeoazts, physical barriers and locks, destruction of paper records, statements <br />requiring staff to sign off on responsibility of customer privacy (and the consequences for <br />not complying j, grad verification of customer provided data with Online Utility Exchange <br />already in place. I and the two staff working with the Online Utility Exchange database <br />reviewed the MMUA template and identified the needed tailoring for our use. <br />Included is the proposed policy for your review. It has been reviewed by our attorney as <br />well. Staff recommends that the commission adopt the policy. <br />