VCOM Institutional Policy and Procedure Manual

Edward Via College of Osteopathic Medicine

Policy Order No.: B004 Effective Date: March 1, 2009 Revised: June 2011

Signature on File ____________________________ Dixie Tooke-Rawlins, D.O. Dean and Executive Vice President

Signature on File ___________________________ James F. Wolfe, Ph.D. President ___________________________________________________________________________________________

VCOM Policy on Red Flag Identity Theft Prevention Program

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1. P URPOSE Edward Via College of Osteopathic Medicine (VCOM) developed the 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. This Program was developed with oversight and approval of VCOM’s Board of Directors.

2.

D EFINITIONS AND P ROGRAM

2.1 Red Flags Rule Definitions Used in this Program “Identity Theft” is a “fraud committed or attempted using the identifying information of another person without authority.”

A “Red Flag” is a “pattern, practice or specific activity that indicates the possible existence of Identity Theft.”

A “Covered Account” includes all student accounts that are administered by the VCOM’s Finance Department. The establishment of covered accounts for students begins when students are accepted by VCOM and identifying information is received and used to establish student records by the Registrar. “Identifying Information” is “any name or number that may be used, alone or in conjunction with any other information, to identify a specific person,” including: name, address, telephone number, social security number, date of birth, government issued driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, computer’s Internet Protocol address, or routing code.