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• activity in accordance with reasonable policies and procedures designed to detect, prevent, and <br />mitigate the risk of Identity Theft. <br />Require, by contract, that service providers have such policies and procedures in place; and <br />Require, by contract, that service providers review the City's Program and report any Red Flags <br />to the Program Administrator. <br />Specific Program Elements and Confidentiality <br />For the effectiveness of Identity Theft prevention Programs, the Red Flag Rule envisions a <br />degree of confidentiality regarding the City's specific practices relating to Identity Theft <br />detection, prevention and mitigation. Therefore, under this Program, knowledge of such specific <br />practices is to be limited to the Identity Theft Committee and those employees who need to know <br />them for purposes of preventing Identity Theft. Because this Program is to be adopted by a <br />public body and thus publicly available, it would be counterproductive to list these specific <br />practices here. Therefore, only the Program's general red flag detection, implementation and <br />prevention practices are listed in this document. <br />PASSED AND APPROVED the 21 st day of October 2008. <br />• <br />SUSAN NARVAIZ, yor, ty f San Marcos <br />ATTEST: <br />SHERRY NC"HBURN, City Secretary <br />APPROVED AS TO <br />City Attorney's <br />SUFFICIENCY: <br /> <br />0