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BOOK 22 Fla 98$ <br />his/her designee will determine whether changes to the policy are warranted. <br />If warranted, the Finance Officer or his/her designee will update the policy <br />and present the Board of Commissioners with recommended changes and the <br />Board will make a determination as to whether to accept, modify or reject <br />those changes to the policy. <br />6. Program Administration <br />a. Oversight - Responsibility for developing, implementing and updating this <br />policy lies with the Finance Officer of his/her designee. The Finance Officer <br />may designate other individuals for ensuring appropriate training of <br />employees on the policy, for reviewing any staff reports regarding the <br />detection of Red Flags and the steps for preventing and mitigating Identity <br />Theft. <br />b. Staff Training and Reports - Employees with access to Covered Accounts <br />shall be trained and made aware of this policy. <br />c. Service Provider Agreements - In the event the County engages a service <br />provider to perform an activity in connection with one or more Covered <br />Accounts, the County will take the following steps to ensure the service <br />provider performs its activity in accordance with reasonable policies and <br />procedures designed to detect, prevent and mitigate the risk of Identity Theft. <br />1. Require, by contract, that service providers have such policies and <br />procedures in place. <br />2. Require, by contract, that service providers review the County's <br />Policy and report any red flags to the Finance Officer or his/her <br />designee. <br />d. Specific Program Elements and Confidentiality - This policy requires a <br />significant degree of confidentiality regarding the County's specific practices <br />relating to Identity Theft detection, prevention and mitigation. Therefore, <br />under this policy, knowledge of such specific practices are to be limited to only <br />those employees who need to know them for purposes of preventing Identity <br />Theft. <br />Conclusions <br />The County will implement the aforementioned systems and procedures to help ensure the <br />confidentiality of financial transactions associated with these types of activities. <br />This policy will be reviewed annually by the Finance Officer or his/her designee. <br />Recommended updates that reflect changes in accounts and services, or its relationship <br />with customers will be brought back to the Board of Commissioners for approval. <br />Identity Theft/Red Flag Rules Page 10 <br />