Updating the Program
The Program will be periodically reviewed and updated to reflect changes in the risks to customers or to the safety and soundness of the University from identity theft, based on factors such as:
- The experiences of the University with identity theft.
- Changes in methods of identity theft.
- Changes in methods to detect, prevent, and mitigate identity theft.
- Changes in the types of accounts that the University offers or maintains.
- Changes in the business arrangements of the University, i.e., joint ventures, new service provider arrangements.