Identity Theft Prevention and Detection Program

After careful examination of our accounts, including the methods by which we open, access and manage customer accounts, along with our past experience with identity theft, the following events/occurrences reasonably indicate the potential for identity theft and should be considered "Red Flags" for purposes of this policy:

A.    Alerts, notifications, or other warnings received from consumer reporting agencies or service providers, such as fraud detections services.  For the purposes of this policy, Pulaski Electric System will be utilizing the ONLINE Utility Exchange as its service provider to identify the “Red Flags” listed below:

1.    A fraud or active duty alert is included with a consumer report.

2.    A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report.

3.    A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant or customer, such as:

a.    A recent and significant increase in the volume of inquiries;
b.    An unusual number of recently established credit relationships;
c.    A material change in the use of credit, especially with respect to recently established credit relationships; or
d.    An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.

B.    The presentation of suspicious documents, such as:

4.    Documents provided for identification appear to have been altered or forged.

5.    The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification.

6.    Other information on the identification is not consistent with information provided by the person opening a new account or customer presenting the identification.

C.    The presentation of suspicious personal identifying information, such as suspicious address changes:

7.    The person opening the account or the customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.

8.    Personal identifying information provided is inconsistent when compared against external information sources used by Pulaski Electric System.

9.    Personal identifying information provided is not consistent with personal identifying information that is on file with Pulaski Electric System.

D.    The unusual use of, or other suspicious activity related to, an account:

10.    Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer's account.

11.    Pulaski Electric System is notified that the customer is not receiving paper account statements.

E.    Notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with accounts held by Pulaski Electric System:

12.    Pulaski Electric System is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.

DETECTION, PREVENTION AND MITIGATION
A.    Detection

In an effort to ensure proper detection of any Red Flags, all customers (consumers) must provide at least the following information/documentation before any new account will be opened:

1.    Full Name;

2.    Date of birth (individual);

3.    Address, (a residential or business street address for an individual; or for a person other than an individual (such as a corporation, partnership, or trust), a principal place of business, local office, or other physical location;

4.    Photo ID provided by a government agency;

5.    Identification number, which shall be: (i) For a U.S. person, a taxpayer identification number; or (ii) For a non-U.S. person, one or more of the following: a taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard; and;

6.    Customer must be willing to allow Pulaski Electric System to review his/her credit report.

For any account holder of an account for which the above information is not already on file at Pulaski Electric System, the customer will be contacted within a reasonable period of time after discovering the missing information to obtain the necessary information.

B.    Preventing and Mitigating Identity Theft

In the event a Red Flag is detected, Pulaski Electric System is committed to preventing the occurrence of identity theft and taking the appropriate steps to mitigate any harm caused thereby. In order to respond appropriately to the detection of a Red Flag, Pulaski Electric System shall consider any aggravating circumstance(s) that may heighten the risk of identity theft. After assessing the degree of risk posed, Pulaski Electric System will respond to the Red Flag in an appropriate manner, which may include:

1.    Monitoring an account for evidence of identity theft;

2.    Contacting the customer;

3.    Changing any passwords, or other security mechanisms that permit access to the customer’s account;

4.    Not opening a new account;

5.    Closing an existing account;

6.    Complying with the prohibitions in 15 U.S.C. 1681m on the sale, transfer, and placement for collection of certain debts resulting from identity theft.

7.    Notifying law enforcement; or

8.    Determining that no response is warranted under the particular circumstances.