Policy – Identity Theft

Policy Statement
Identity Theft is a crime in which an individual wrongfully obtains and uses another person’s personal data, usually for economic gain, in some way involving deception or fraud. This Policy attempts to reduce potential Identity Theft risks to our publishing community, clients, and vendors.

Company leadership and managers are trained to identify, detect, prevent and mitigate potential Identity Theft risks. The indicators of Identity Theft are known as “Red Flags”.

Policy

Policy Text
Advontemedia acknowledges the crucial importance of its regulatory responsibilities and all reports of Identity Theft will be investigated and acted upon, up to and including the involvement of law enforcement agencies, when required.

The Identity Theft Prevention Policy:
The policy contains reasonable procedures designed to educate company leaders and managers to:
Identify relevant Red Flags for new and existing Covered Accounts;
Detect Red Flags;
Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity Theft;

Identity Theft Prevention Leadership:
Officers will review this policy annually as a corporate meeting agenda item and update when necessary at other times on an ongoing basic.

As of 2022, this policy is now part of the annual meeting agenda.

Responsibilities
Corporate officers must approve the Identity Theft Prevention Policy.

Definitions
“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.”
Examples of Red Flags include, but are not limited to:

• Alerts or notifications from consumer reporting agencies or service providers, such as fraud detection services
• Presentation of suspicious documents, such as identification documents which have been forged or altered
• Presentation of suspicious personal identifying information, such as unauthorized or unwarranted change to: account information, address or social security number
• Unusual use of or other suspicious activity relating to a Covered Account, such as identification of use of an account in a manner inconsistent with established patterns of activity on the account
• Notices from customers, victims of Identity Theft, law enforcement, or other persons regarding Identity Theft in connection with Covered Accounts held by the creditor

A “Covered Account” is an account the Company offers or maintains that permits multiple transactions or poses a reasonably foreseeable risk of being used to promote an Identity Theft. Such an account may be identified as potentially posing a reasonably foreseeable risk of Identity Theft to clients, employees and other relevant third parties, including financial, operational, compliance, reputation, or litigation risks. For purposes of this policy, this may include, but are not limited to:
– Certain client accounts
– Certain potential employee information

“Personally Identifiable 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, and computer’s Internet Protocol address.

Contacts
Any questions or inquiries with respect to the administration of this policy should be directed to a company officer and/or any incidents may be reported by contacting 1-951-256-4944.