Fort Hays State University > About FHSU > Academic Divisions > Office of the Provost > Faculty and Unclassified Handbook > Ch 1 Identity Theft
Office of the Provost
In late 2007 the Federal Trade Commission implemented regulations requiring financial institutions and other creditors to develop policies and procedures to identify detect and respond appropriately to Red Flags of identity theft. The regulations also require users of consumer reports to develop policies and procedures designed to enable the user to form a reasonable belief that a consumer report relates to the consumer about whom it has requested the report when the user receives a notice of address discrepancy. In addition, identity theft has become prevalent in today’s society, and poses significant risk to consumers, including students of Fort Hays State University. Therefore, Fort Hays State University hereby implements this program in order to comply with applicable regulations, to protect students and other consumers of FHSU’s services from identity theft, and to mitigate the effects of such when it does occur.
“Identity Theft” is a fraudulent or attempted use of identifying information of another person without such person’s authority.
A "Red Flag" means a pattern, practice, or specific activity that indicates the possible existence of identity theft.
"Covered Account" means all student accounts or loans administered by FHSU that involve or are designed to permit multiple payments or transactions, and accounts for business, personal, family and household purposes for which there is a reasonably foreseeable risk of identity theft. For purposes of this program, examples of covered accounts maintained or offered by FHSU include but are not limited to:
"Consumer" as used herein means the holder of a covered account or a person on whom a consumer report has been sought.
Identifying Red Flags
In identifying Red Flags on covered accounts, FHSU will take the following into consideration:
Examples of Red Flags
Detecting Red Flags
In order to attempt to detect Red Flags, FHSU will obtain identifying information about the person opening a covered account and attempt to verify such person’s identity to the extent reasonable and possible, by comparing the information received with other
information on the same person maintained by FHSU. In addition, FHSU may take one or more of the following actions to detect Red Flags:
Responding to Red Flags
When FHSU has detected a possible Red Flag associated with a covered account, the administrator of the Program may take one or more of the following actions:
Updating the Program
FHSU will review the program periodically, and no less than once per year, to determine whether updates and modifications are needed based upon experience with identifying and responding to Red Flags. Also, the program will be reviewed and updated if FHSU becomes aware of changes in methods of committing, preventing and/or detecting identity theft. Finally, changes in the type or nature of accounts that FHSU maintains and particular business arrangements of FHSU may require an update to the program.
Administering the Program
This program has been approved by the President's Cabinet on the date indicated at the end of this document. Oversight for the program is delegated to the Vice President for Administration and Finance or designee. The Vice President for Administration and Finance or designee will review reports prepared by staff regarding any particular circumstances throughout the year when Red Flags were detected, and shall recommend and implement updates and changes to the program as needed.
Oversight of Service Provider Relationships
The Vice President for Administration and Finance or designee shall also be responsible for oversight of service provider arrangements, making sure that financial institutions or creditors engaged by FHSU to perform an activity in connection with one or more covered accounts are complying with applicable regulations relating to Red Flags for identity theft and address discrepancies (example: FHSU's vendor for student banking services). The person responsible for such oversight on FHSU’s behalf will at a minimum contact the vendor to discuss the vendor’s policies and practices pursuant to the Red Flags rules, and will periodically review the vendor’s reports of detected Red Flags on accounts relating to the University, and will examine the vendor’s response thereto.
Address DiscrepanciesA notice of address discrepancy means a notice sent to FHSU by a consumer reporting agency, that informs FHSU of a substantial difference between the address provided to request a consumer report for the person for whom the consumer report was requested and the address in the vendor's file for such person.
Action Steps When a Notice of Address Discrepancy is Received
FHSU will take one or more of the following actions to enable it to form a reasonable belief that a consumer report relates to the consumer about whom it has requested the report when a notice of address discrepancy is received:
Action Steps When an Address has been Found to be Accurate
When FHSU has reasonably confirmed an address for the consumer is accurate, FHSU will furnish such address to the consumer reporting agency as part of the information that FHSU regularly furnishes the next time it provides information. When FHSU has confirmed an address for a consumer after receiving a notice of an address discrepancy, it will provide the confirmed address to the vendor the next time FHSU provides information to the vendor.
Action Steps When an Address cannot be Verified
If FHSU receives notice of an address discrepancy in connection with one of its covered accounts as defined above, it will follow the policies and procedures relating to Red Flags for identity theft. FHSU will inform such person that the address provided by the consumer reporting agency is inconsistent with the address provided by the person or maintained by FHSU, and through this policy advises such persons to take appropriate steps to guard their identity and mitigate any possible harm that has been or could be caused as a result of identity theft.
Adopted by President’s Cabinet (06/17/09).
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