Red Flag Requirements

Red Flag Requirements

Identify relevant patterns, practices, and specific forms of activity that are "red flags" signaling possible identity theft and incorporate those red flags into the Program;
Detect red flags that have been incorporated into the Program;
Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
Ensure the Program is updated periodically to reflect changes in risks from identity theft.

The requirements as set forth by the FTC all revolve around the creation of a "Program." As the saying goes, "the devil is in the details." The creation of a program and tailoring it to a specific company and/or department is critical.

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