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well. Escalate problematic customers who resist requests for identity verification to your Program Manager and continue to seek additional information or ask more out-of-wallet questions. Make sure your ITPP program has a process for documenting your ITPP activities for each credit customer. Do ongoing training and periodic testing of your ITPP. Refine and update your Program as new information about identity theft comes to your attention. Don’t forget about holding an annual Program review for participating employees and making an annual report to your Board of Directors and senior managers. 10. Educate your employees about the risks of identity theft and social networking attacks. As email spam filters have become more sophisticated, fraudsters have turned to other socially engineering methods that prey on consumers’ trust. Tell employees not to click on any Internet link unless they are certain of the legitimacy of the source. Emails purporting to be genuine from friends, law enforcement, or trusted institutions may contain links that unload malware onto the employee’s PC and network if clicked on. Additional Resources FTC Business Security Guide: www.ftc.gov/tips-advice/business-center/guidance/start-security-guide-business FTC Safeguards Rule: www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/safeguards-rule www.ftc.gov/news-events/press-releases/2019/05/ftc-extends-comment-deadline-proposed-changes- safeguards-rule FTC’s Identity Theft Website: www.identitytheft.gov Department of the Treasury, information and links to the OFAC SDN List: www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx OFAC – Assessing SDN List Matches for a Customer www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_compliance.aspx#match Searchable OFAC List – a site that lets you enter a business name to see if it matches an entry on the OFAC list: www.instantofac.com FTC Consumer Information Disposal Rule : www.ftc.gov/tips-advice/business-center/guidance/disposing-consumer-report-information-rule-tells-how State Data Security Breach Notification Laws: www.ncsl.org/research/telecommunications-and-information-technology/security-breach-notification-laws Information Compromise and the Risk of Identity Theft: FTC Guidance for Your Business: www.ftc.gov/tips-advice/business-center/guidance/information-compromise-risk-identity-theft-guidance-your Social Security Randomization: www.ssa.gov/employer/randomization.html

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Information provided Courtesy of Dealertrack Technologies 888.705.7926; www.dealertrack.com