Procedure

Covered Account – A covered account is a consumer account designed to permit multiple payments or transactions.  These are accounts where payments are deferred and made by a borrower periodically over time such as a tuition or fee installment payment plan.

Creditor – A creditor is a person or entity that regularly extends, renews, or continues credit and any person or entity that regularly arranges for the extension, renewal, or continuation of credit.  Examples of activities that indicate a college or college is a “creditor” are:

1. Participation in the Federal Perkins Loan program;
2. Participation as a school lender in the Federal Family Education Loan Program;
3. Offering loans to students, faculty or staff;
4. Offering a plan for payment of tuition or fees throughout the semester rather than requiring full payment at the beginning of the semester.

Identifying Information – Any name or number that may be used, alone or in conjunction with any other information, to identify a specific person including: name, address, telephone number, social security number, date of birth, government issued driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, computer’s Internet Protocol address, routing code or financial account number such as credit card number, in combination with any required security code, access code, or password that would permit access to an individual’s financial account.

Red Flag – A red flag is a pattern, practice or specific activity that indicates the possible existence of identity theft.

Security Incident – A collection of related activities or events which provide evidence that personal information could have been acquired by an unauthorized person.

Review/Amended: