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Continue to monitor an account for evidence of Identity Theft; <br />Contact the customer; <br />Change any passwords or other security devices that permit access to accounts; <br />Not open a new account; <br />Close an existing account; <br />Reopen an account with a new number; <br />Notify the Program Administrator for determination of the appropriate step(s) to take; <br />Notify law enforcement; or <br />Determine that no response is warranted under the particular circumstances. <br />PROGRAM UPDATES <br />This Program will be periodically reviewed and updated to reflect changes in risks to customers <br />and the soundness of the City from Identity Theft. At least annually, the Program Administrator <br />will consider the City's experiences with Identity Theft situation, changes in Identity Theft <br />methods, changes in Identity Theft detection and prevention methods, changes in types of <br />accounts the City maintains and changes in the City's business arrangements with other entities. <br />After considering these factors, the Program Administrator will determine whether changes to <br />the Program, including the listing of Red Flags, are warranted. If warranted, the Program <br />Administrator will update the Program or present the San Marcos City Council with <br />recommended changes and the San Marcos City Council will make a determination of whether to <br />accept, modify or reject those changes to the Program. <br />PROGRAM ADMINISTRATION • <br />Oversight <br />Responsibility for developing, implementing and updating this Program lies with the Program <br />Administrator. The Program Administrator will be responsible for the Program administration, <br />for ensuring appropriate training of City staff on the Program, for reviewing any staff reports <br />regarding the detection of Red Flags and the steps for preventing and mitigating Identity Theft, <br />determining which steps of prevention and mitigation should be taken in particular circumstances <br />and considering periodic changes to the Program. <br />Staff Training and Reports <br />City staff responsible for implementing the Program shall be trained either by or under the <br />direction of the Program Administrator in the detection of Red Flags, and the responsive steps to <br />be taken when a Red Flag is detected. <br />Service Provider Arrangements <br />In the event the City engages a service provider to perform an activity in connection with one or <br />more accounts, the City will take the following steps to ensure the service provider performs its <br />• <br />4