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• Assignment of specific responsibility for implementation of the Program <br />to the Department's Finance Manager; <br />• Review of reports prepared by staff regarding compliance; and <br />• Approval of material changes to the Program as necessary to address <br />changing risks of identity theft. <br />2. Reports shall be prepared as follows: <br />The Department's Customer Service Staff is responsible for development, <br />implementation and administration of the Program. They shall report to the <br />Department Finance Manager at least annually on compliance by the Department <br />with the Program. The report shall address material matters related to the <br />Program and evaluate issues such as: <br />• The effectiveness of the policies and procedures in addressing the risk <br />of identity theft in connection with the opening of covered accounts <br />and with respect to existing covered accounts; <br />Service provider agreements; <br />Significant incidents involving identity theft and management's <br />response; and <br />• Recommendations for material changes to the Program. <br />Oversight of Service Provider Arrangements <br />In the event the Department engages a service provider to perform an activity in <br />connection with one or more accounts, it will take the following steps to ensure the <br />service provider performs its activity in accordance with reasonable policies and <br />procedures designed to detect, prevent, and mitigate the risk of identity theft: <br />• Require, by contract, that service providers have such policies and <br />procedures in place; and <br />• Require, by contract, that service providers review the Department's <br />Program and report any Red Flags to the Program Administrator. <br />Duties Regarding Address Discrepancies <br />The Department shall develop policies and procedures designed to enable the Department <br />to form a reasonable belief that a credit report relates to the consumer for whom it was <br />requested if the Department receives a notice of address discrepancy from a nationwide <br />consumer reporting agency indicating the address given by the consumer differs from the <br />address contained in the consumer report. <br />The Department may reasonably confirm that an address is accurate by any of the <br />following means: <br />• Verification of the address with the consumer; <br />6 <br />42 <br />