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6. Reopen an account with a new number; <br />7. Notify the Program Administrator for determination of the appropriate step(s) to take; <br />8. Notify law enforcement; or <br />9. Determine that no response is warranted under the particular circumstances. <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 operating <br />procedures to protect customer identifying information: <br />1. Ensure that its website is secure or provide clear notice that the website is not secure; <br />2. Ensure complete and secure destruction of paper documents and computer files <br />containing customer information; <br />3. Ensure that office computers are password protected and that computer screens lock after <br />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 kinds of customer information that are necessary for utility <br />purposes. <br />7. Have all staff with access to protected information sign off on a customer privacy <br />understanding statement which states that a violation of customers' privacy results in <br />consequences up to, and including, possible termination. <br />VI. PROGRAM UPDATES <br />The Program Administrator will periodically review and update this Program to reflect <br />changes in risks to customers and the soundness of the Utility from Identity Theft. In doing so, <br />the Program Administrator will consider the Utility's experiences with Identity Theft situations, <br />changes in Identity Theft methods, changes in Identity Theft detection and prevention methods, <br />and changes in the Utility's business arrangements with other entities. After considering these <br />factors, the Program Administrator will determine whether changes to the Program, including the <br />listing of 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 and the <br />Utility Commission will make a determination of whether to accept, modify or reject those <br />changes to the Program. <br />VII. PROGRAM ADMINISTRATION. <br />A. Oversight <br />6 <br />