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Identity theft means fraud committed using the identifying information of another person without authority. Red Flag means a pattern, practice or specific activity that indicates the possible existence of identity theft. The Program The Department establishes an Identity Theft Prevention Program (Program) to detect, prevent and mitigate identity theft. The Program shall include reasonable policies and procedures to: 1. Identify relevant Red Flags for covered accounts it offers or maintains and incorporate those Red Flags into the program; 2. Detect Red Flags that have been incorporated into the Program; 3. Respond appropriately to any Red Flags that are detected to prevent and mitigate identity theft; and 4. Ensure that the Program is updated periodically to reflect changes in risks to customers and to the safety and soundness of the Department from identity theft. The Program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks. Identification of Relevant Red Flags In order to identify relevant Red Flags, the Department considers the types of accounts that it offers and maintains, the methods it provides to open its accounts, the methods it provides to access its accounts and its previous experience with identify theft. The Department identifies the following Red Flags, in each of the listed categories: 1. Notifications and Warnings from Credit Reporting Agencies • Report of fraud accompanying a credit report; • Notice or report from a credit agency of a credit freeze on a customer or applicant; • Notice or report from a credit agency of an active duty alert for an applicant; and • Indication from a credit report of activity that is inconsistent with a customer's usual pattern or activity. 2. Suspicious Documents • Identification document or card that appears to be forged, altered or inauthentic; 2 38