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Red Flag Policy

Bursar Department

Protecting your privacy is of paramount importance at Missouri Southern State University, and we are dedicated to the responsible handling of  your personal information.  We are very committed to following our privacy policies and complying with the law.

Missouri Southern State University (“University”) developed this Identity Theft Prevention Program ("Program") pursuant to the Federal Trade Commission's (“FTC”) Red Flags Rule, which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003.

These rules became effective August 1, 2009, and require certain agencies to implement an identity theft program and policy.

IDENTITY THEFT POLICY

SECTION 1: BACKGROUND

The risk to the University, its employees and students from data loss and identity theft is of significant concern to the University and can be reduced only through the combined efforts of every employee and contractor.

SECTION 2: PURPOSE

The University adopts this sensitive information policy to help protect employees, customers, students, contractors and the University from damages related to the loss or misuse of sensitive information.

This policy will:

This policy enables the University to protect existing customers, reducing risk from identity fraud, and minimize potential damage to the University from fraudulent new accounts. The program will help the University:

SECTION 3: SCOPE

This policy and protection program applies to employees, contractors, consultants, temporary workers, and other workers at the University, including all personnel affiliated with third parties.

SECTION 4: POLICY

4.A: Sensitive Information Policy

4.A.1: Definition of Sensitive Information

Sensitive information includes the following items whether stored in electronic or printed format:

4.A.1.a: Credit card information, including any of the following:

4.A.1.b: Tax identification numbers, including:

4.A.1.c: Payroll information, including, among other information:

4.A.1.d: Cafeteria plan check requests and associated paperwork

4.A.1.e: Medical information for any employee or customer, including but not limited to:

4.A.1.f: Other personal information belonging to any customer, employee or contractor, examples of which include:

4.A.1.g: University personnel are encouraged to use common sense judgment in securing confidential information to the proper extent. Furthermore, this section should be read in conjunction with the Missouri Sunshine Act. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact their supervisor. In the event that the University cannot resolve a conflict between this policy and the Missouri Sunshine Act contact appropriate legal counsel for guidance.

4.A.2: Hard Copy Distribution

Each employee and contractor performing work for the University will comply with the following policies:

4.A.3: Electronic Distribution

Each employee and contractor performing work for the University will comply with the following policy:

“This email may contain identifiable personal information that is subject to protection under state and federal law.  This information is intended for the use of the individual named above.  If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited and may be punishable by law.  If you have received this electronic transmission in error, please notify us immediately by electronic mail (reply).”

 

SECTION 5: ADDITIONAL IDENTITY THEFT PREVENTION PROGRAM

If the University maintains certain covered accounts pursuant to federal legislation, the University may include the additional program details.

5.A: Covered accounts

A covered account includes any account that involves or is designed to permit multiple payments or transactions. Every new and existing customer account that meets the following criteria is covered by this program:

5.B: Red flags

5.B.1: The following red flags are potential indicators of fraud. Any time a red flag, or a situation closely resembling a red flag, is apparent, it should be investigated for verification.

5.B.2: Red flags also include consumer reports that indicate a pattern of activity inconsistent with the history and usual pattern of activity of an applicant or customer, such as:

5.C: Suspicious documents

5.C.1: Documents provided for identification that appear to have been altered or forged.

5.C.2: The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification.

5.C.3: Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification.

5.C.4: Other information on the identification is not consistent with readily accessible information that is on file with the University, such as a signature card or a recent check.

5.C.5: An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.

5.D: Suspicious personal identifying information

5.D.1: Personal identifying information provided is inconsistent when compared against external information sources used by the University. For example:

5.D.2: Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the University. For example, the address on an application is the same as the address provided on a fraudulent application

5.D.3: Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the University. For example:

5.D.4: The SSN provided is the same as that submitted by other persons opening an account or other customers.

5.D.5: The address or telephone number provided is the same as or similar to the address or telephone number submitted by an unusually large number of other customers or other persons opening accounts.

5.D.6: The customer or the person opening the covered account fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.

5.D.7: Personal identifying information provided is not consistent with personal identifying information that is on file with the University.

5.D.8: When using security questions (mother’s maiden name, pet’s name, etc.), the person opening the covered account or the customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.

5.E: Unusual use of, or suspicious activity related to, the covered account

5.E.1: Shortly following the notice of a change of address for a covered account, the University receives a request for new, additional, or replacement goods or services, or for the addition of authorized users on the account.

5.E.2: A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns. For example, the customer fails to make the first payment or makes an initial payment but no subsequent payments

5.E.3: A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example:

5.E.4: A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors).

5.E.5: Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s covered account.

5.E.6: The University is notified of unauthorized charges or transactions in connection with a customer’s covered account.

5.E.7: The University receives notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the University

5.E.8: The University is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.

SECTION 6: RESPONDING TO RED FLAGS

6.A: Once potentially fraudulent activity is detected, an employee must act quickly as a rapid appropriate response can protect customers and the University from damages and loss.

6.A.1: Once potentially fraudulent activity is detected, gather all related documentation and write a description of the situation. Present this information to the designated authority for determination.

6.A.2: The designated authority will complete additional authentication to determine whether the attempted transaction was fraudulent or authentic.

6.A.3: The designated authority for such notification shall be the University’s Assistant Vice President of Academic Affairs and/or Assistant Vice President of Business Affairs.

6.B: If a transaction is determined to be fraudulent, appropriate actions must be taken immediately. Actions may include:

SECTION 7: PERIODIC UPDATES TO PLAN

7.A: At periodic intervals established in the program, or as required, the program will be re-evaluated to determine whether all aspects of the program are up to date and applicable in the current business environment.

7.B: Periodic reviews will include an assessment of which accounts are covered by the program.

7.C: As part of the review, red flags may be revised, replaced or eliminated. Defining new red flags may also be appropriate.

7.D: Actions to take in the event that fraudulent activity is discovered may also require revision to reduce damage to the University and its customers.

SECTION 8: PROGRAM ADMINISTRATION

8.A: Involvement of management

8.B: Staff Notification

8.C: Oversight of service provider arrangements

Any specific requirements should be specifically addressed in the appropriate contract arrangements.

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