HomeMy WebLinkAboutRESO 9114Resolution No. 9114
Resolution of the Council of the City of Palo Alto Approving
Changes to the City of Palo Alto Utilities Procedures for
Customer Credit Security in Accordance with the Fair and
Accurate Credit Transactions Act of 2003
WHEREAS, Federal Trade Commi~sion (FTC) regulations under the Fair and
Accurate Credit Transactions Act (FACT Act) require entities which affect consumer credit to
evaluate. and possibly create a formal program to detect, prevent, and mitigate identity theft by
November 1, 2009; and /
WHEREAS, a public utility is considered to offer or maintain accounts covered
under the FACT Act; and
WHEREAS, in 2008 the City of Palo Alto Utilities (CP AU) conducted a risk
assessment to determine whether the accounts it maintains are subject to a reasonably
foreseeable risk of identity theft, including a review of (1) the methods used to open accounts,
(2) the methods of accessing accounts, and (3) previous experiences with identity theft; and
WHEREAS, as part of the risk assessment, CP AU identified relevant "red flags"
defined as patterns, practices or specific activities that indicate the possible existence ofidentity
theft and created a set of "Prqcedures for Customer Credit Security" ("Security Procedures");
and
WHEREAS, Council adopted CPAU's Security Procedures via Resolution No. 8857
on September 15, 2008, and appointed the Director of Utilities to provide day to day oversight
and report on the Security Procedures annually to Council; and
WHEREAS, CP AU reviewed its processes for opening, maintaining and accessing
covered accounts during the last twelve months and identified new processes for immediate
incorporation in the Security Procedures; and
WHEREAS, CP AU presented the updated Security Procedures and annual report to
the Utilities Advisory Commission (UAC) on September 2,2009 and to Council on October 5,
2009 and
NOW, THEREFORE, the Council of the City of Palo Alto does RESOLVE as
follows:
SECTION 1. The Council hereby approves the changes to the attached
"Procedures for Customer Credit Security" in compliance with the FACT Act.
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SECTION 2. The Council finds that the adoption of this resolution does not
constitute a project under Section 21065 of the California Environmental Quality Act and the
CEQA Guidelines and, therefore, no environment assessment is required.
INTRODUCED AND PASSED: November 8, 2010
AYES: BURT, ESPINOSA, HOLMAN, KLEIN, PRICE, SCHARFF, SCHMID,
SHEPHERD,YEH
NOES:
ABSENT:
ABSTENTIONS:
~4 ayor .
APPROVED AS TO FORM: APPROVED:
e.~~&;:LJJ Seruor eputy CIty Attorney·
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101110 syn 6050968