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(c) the “Red Flags” Rule (consumer credit information: identity theft prevention).

Introduction

Red Clay Renovations has done an excellent job growing and maturing the company. We have made great strides in modernizing the company and the methods utilize to better assist and protect our clientele. In order to fulfill our renovation projects, we are tasked with collecting, managing, processing, and storing our clients Personally Identifiable Information (PII) and the way it is handled and protected is paramount. This creates additional risks and is why it is critical to have policies implemented that clearly states how this daunting task is carried out. To help mitigate the risk of our clients PII from being compromised we will need to implement the Red Flags Rule. The Red Flags Rule was created around 2010 and requires companies or organizations to establish a written identity theft prevention program, which is designed to identify “red flags” of potential identity theft occurring in day-to-day operations, and to demonstrate the steps taken to mitigate the damage of the threat (FTC, 2013). To better understand how the Red Flags Rule will better assist us in protecting our clients and even our own PII, the four basic elements that make up its framework and scenarios to how it applies to Red Clay Renovations are described below.

Analysis

Implementing the Red Flags Rule is an important component required to mitigate IT security issues for companies like Red Clay Renovations that collect, manage, process, and store PII. The Red Flags Rule allots flexibility for a company or organization to be able to customize its framework to design a program that is appropriate for its size and potential risks of identity theft (FTC, 2013). The included steps are:

  • Identify red flags of relevant types of identity theft for your company.
  • Detect the red flags when they occur.
  • Respond to the red flags appropriately.
  • Update the identity theft program periodically.

(SEC, 2013).

Now to examine how these four basic elements of the Red Flags Rule pertains to Red Clay Renovations and can be implemented to improve our security efforts towards protecting PII of our clients and our personnel. First, a scenario Red Clay would encounter is the risk of compromise of the PII collected on our clients, such as family information (including medical information to better assist with design plans to best meet needs of a disable customer), credit checks, and financial data. Noticing irregularities in identification records that deviate from our other required information is a big red flag that should be noted and monitor for. To analyze the red flag, it can be crossed referenced with credit check information and by conducting a more in-depth information check on the client to confirm the suspicious irregularities. For the second element, detecting the occurring red flag/flags, Red Clay must constantly be vigilant in their efforts to notice any irregularities of a client’s personal data (ID, Check, Documents). To better detect this red flag, Red Clay must establish a protocol and detect process to simplify and improve the efficiency of the manner red flags are detected; including the process of analyzing clientele payment history and their method of payment. If the irregularity is detected and flagged, it will be assigned for the next element. The third element for the Red Flags Rule is to respond appropriately to the detected red flag. For a red flag representing possible identity theft, Red Clay should respond by contacting the account holder to inform them of the situation and recommend them to update their information to better help Red Clay protect their information and finances. In addition, Red Clay will need to assure the client, that they will do everything in their power to resolve this current situation. Ensuring this communication with the client is conducted will allot Red Clay to reevaluate the collected data on the client and assists with updating the identity theft program and helps ensure that any additional red flags are detected (FindLaw, n.d.).

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