The Red Flag regulations list the four core elements that must be included in the program of a financial institution or creditor. Willamette University has incorporated the following four core elements into its program:
- Identifying Relevant Red Flags: The University will identify relevant red flags for the covered accounts that it offers or maintains and incorporate those red flags into its program.
- Detecting Red Flags: The University will detect and record red flags that have been incorporated into its program.
- Preventing and Mitigating Identity Theft: The University will respond appropriately to any red flags that are detected to prevent and mitigate identity theft.
- Updating the Program: The University will periodically update the program to reflect changes in risks to customers and to the safety and soundness of the University in its role as creditor.
The University's program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.