Policy:

1. The College establishes an Identity Theft Prevention Program to detect, prevent and mitigate identity theft. The Program shall include reasonable steps to:
   1. Identify relevant red flags for covered accounts the College offers or maintains and incorporate those red flags into the program;
   2. Detect red flags that have been incorporated in the Program;
   3. Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
   4. Ensure that the Program is updated periodically to reflect changes in risks to customers and to the safety and soundness of the College from identity theft.
2. The President shall cause a procedure to be developed to implement this policy.