HomeMy WebLinkAboutStaff Report 6231
City of Palo Alto (ID # 6231)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 2/8/2016
City of Palo Alto Page 1
Summary Title: 2016 Update of the Utilities 2010 Procedures for Customer
Identity and Credit Security
Title: Staff Recommendation That the City Council Adopt a Resolution
Approving the “2016 Procedures for Customer Identity and Credit Security”
From: City Manager
Lead Department: Utilities
RECOMMENDED MOTION
Staff recommends that Council consider the following motion:
The Council hereby adopts a resolution approving the Utilities Department’s “2016 Procedures
for Customer Identity and Credit Security”.
RECOMMENDATION
Staff recommends that Council adopt a resolution approving the “2016 Procedures for
Customer Identity and Credit Security” (the Procedures).
EXECUTIVE SUMMARY
Since the original adoption of the Procedures in 2008, and subsequent updates reflecting
changes to Utilities business practices after implementation of SAP in 2009, there have not
been any verified instances of CPAU customer identity or theft of credit information, or
substantive changes required to the Procedures
The proposed 2016 update to the 2010 Procedures:
Appoints the City Manager (rather than Council) as the Administrator of the Identity and
Credit Security Program (Program) and the Procedures for Customer Identity and Credit
Security (Procedures);
Authorizes the Administrator (rather than Council) to be responsible for oversight,
development, implementation, reporting, and future revisions of the Program and
Procedures; and,
Authorizes the Administrator to coordinate the data security provisions of the Program
and Procedures with the Information Technology Department’s requirements for the
Information Security Policy and Information Privacy Policy.
City of Palo Alto Page 2
DISCUSSION
There are multiple state and federal mandates supporting cybersecurity, identity theft
protection and response, and consumer credit security. Enacted over the past several years,
they target business and consumer data, financial infrastructure, data access, online and
physical controls, staff training, security breaches, incident management and organizational
compliance.
The City of Palo Alto adopted a formal program for customer identity and credit theft
protection in 2008 ((Procedures). These guidelines and actions were designed to correspond
with the patterns, practices or specific identity and credit security activities identified by the
“Fair and Accurate Credit Transactions Act of 2003” (FACT Act) that could indicate the possible
existence of CPAU customer identity theft.
The purpose of the FACT Act legislation was to provide consumers with additional tools to fight
the growing crimes of identity and credit theft. The FACT Act required City of Palo Alto Utilities
Department (CPAU) to create a formal program for the identification, detection, response and
mitigation of specific business practices (or “red flags”) that could indicate an instance of
identity theft impacting CPAU customers.
CPAU complies with the requirements of the FACT Act, because it continues to qualify as a
“creditor” under federal regulations (service in advance of payment). The proposed
reassignment of duties better reflects the administrative and operational nature of the required
responsibilities. While retaining interdepartmental checks and balances and citywide
consistency, delegation of responsibility clarifies roles and facilities program modification may
be needed to address future threats.
NEXT STEPS
The City Manager will assume administration of the Procedures, and staff will continue to
review CPAU business processes report compliance with FACT Act requirements, and
incorporate improvements for customer identity and credit security into future updates of the
Procedures.
RESOURCE IMPACT
There is no impact on Utilities sales, revenues or budgets.
POLICY IMPLICATIONS
Adoption by Resolution will update the “2010 Procedures for Customer Identity and Credit
Security,” and delegate future oversight and administrative functions for the “2016 Procedures”
to the City Manager.
City of Palo Alto Page 3
ENVIRONMENTAL REVIEW
Council’s adoption of a resolution updating the Procedures does not meet the definition of a
project, pursuant to Section 21065 of the California Environmental Quality Act, thus no
environmental review is required.
Attachments:
Attachment A: Draft 2016 Procedures for Customer Identity and Credit Security - CLEAN
Version (PDF)
Attachment B: Draft 2016 Procedures for Customer Identity and Credit Security -
REDLINED Version (PDF)
Attachment C: Draft Resolution Adopting the 2016 Procedures for Identity and Credit
Security (PDF)
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Proposed Effective Date: February 8, 2016
City of Palo Alto Utilities
DRAFT
2016 Procedures for
Customer Identity and Credit Security
ATTACHMENT A
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Proposed Effective Date: February 8, 2016
2016 Procedures for
Customer Identity and Credit Security
SECTION PAGE
1. Policy Statement 3
2. Utilities Identity and Credit Theft Prevention 4
A. Definitions 4
B. The Red Flag Rule 4
C. Identity and Credit Theft Program Adoption 5
(Procedures)
D. Requirements of the Procedures 5
3. Administration of the Procedures for Customer
Identity and Credit Security 6
4. Customer Identity and Credit Information,
Systems and Access 7
A. Classification of Information
B. Utilities Customer Information Systems 7
C. Identity and Credit Information Access 8
5. Identification, Detection, Response and
Mitigation of Red Flags 10
A. Customer Service 10
B. Billing and Payment 11
C. Credit and Collection 13
D. Other City Departments 14
End
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Proposed Effective Date: February 8, 2016
1. Policy Statement
The City of Palo Alto shall ensure that proprietary and confidential Utilities customer
information is secure from identity theft as required by law and business practice.
The Fair Credit Reporting Act, 15 United States Code, Section 1681 ET. seq., was
amended to include the Fair and Accurate Credit Transactions Act of 2003 (Public
Law 108-159), hereinafter referred to as the FACT Act.
The FACT Act requires those businesses and organizations which can affect
consumer credit to create a formal program to detect, prevent, respond and
mitigate potential identity theft before December 31, 2010.
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Proposed Effective Date: February 8, 2016
2. Utilities Identity and Credit Theft Prevention
The Fair and Accurate Credit Transaction Act of 2003 (FACT Act) requires those
entities which can affect consumer credit to create a formal identity theft
prevention program to detect, prevent and mitigate identity theft before December
31, 2010.
A. Definitions
The “Red Flag Rule” is a set of United States federal regulations that require
certain businesses and organizations identified as “creditors” to develop and
implement documented plans to protect consumers from identity theft.
“Identity theft' means a fraud committed using the identifying information of
another person.
A “creditor” is any entity that regularly extends, renews, or continues credit; any
entity that regularly arranges for the extension, renewal, or continuation of
credit; or any assignee of an original creditor who is involved in the decision to
extend, renew, or continue credit. Accepting credit cards as a form of payment
does not in and of itself make an entity a creditor. Creditors include finance
companies, automobile dealers, mortgage brokers, utility companies, and
telecommunications companies. Where non-profit and government entities
defer payment for goods or services, they, too, are to be considered creditors.
Only those financial institutions and creditors that offer or maintain "covered
accounts" must develop and implement a written Program.
A "covered account" is either: an account primarily for personal, family, or
household purposes; that involves or is designed to permit multiple payments or
transactions, such as a credit card account, mortgage loan, car loan, margin
account, cell phone account, utility account, checking account, or savings
account; or any other account for which there is a reasonably foreseeable risk to
customers or creditor from identity theft.
An “Identity Theft Report” alleges an identity theft; is a copy of an official, valid
report filed by a consumer with an appropriate Federal, State, or local law
enforcement agency, including the United States Postal Inspection Service; and,
subjects the person filing the report to criminal penalties relating to the filing of
false information if, in fact, the information in the report is false.
B. Red Flag Rule
There are a total of twenty-six individual red flags comprising the Red Flag Rule,
with five categories of common red flags:
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Proposed Effective Date: February 8, 2016
1. Alerts, notifications, and warnings from a credit reporting company, including
address discrepancies.
2. Suspicious documents that look like they have been altered or forged, or that
the information or description does not match the applicant or customer.
3. Suspicious personal identifying information, including inconsistent data.
4. Suspicious account activity, including name changes, unauthorized charges or
address changes for credits or refunds.
5. Notification by another source, including a customer, another victim of
identity theft, a law enforcement authority, or other person regarding an
account having an Identity heft Report completed, or other notice that an
account may have been compromised by identity theft.
C. Identity and Credit Theft Program Adoption (Procedures)
The City Council of Palo Alto adopted the Utilities Department formal identity
and credit theft prevention program entitled “Procedures for Customer Credit
Security” (Procedures) on September 3, 2008. The Procedures focus on red flags
-defined as patterns, practices, or specific activities that indicate possible
existence of identity theft on a covered account.
D. Requirements of the Procedures
The Procedures were designed to:
1. Identify red flags for covered accounts and incorporate those red flags into
the Procedures
2. Detect red flags that have been incorporated into the Procedures
3. Respond appropriately to any red flags that are detected
4. Mitigate the occurrence of identity or credit theft
5. Ensure the Procedures are updated annually, to reflect the changes in
identity or credit theft risk
6. Provide for administration and update of the Procedures with red flags
identified and incorporated into specific operational and transactional
policies and procedures for City departments with access to confidential
Utilities customer data.
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Proposed Effective Date: February 8, 2016
3. Administration of the Procedures for Customer Identity and Credit
Security
The Palo Alto City Council shall provide for the continued administration of the
Procedures. This includes:
1. Approval of the initial written Procedures by Council;
2. Designating the City Manager as Administrator for oversight, development,
implementation and administration of the Procedures;
3. As Administrator for the Procedures, the City Manager shall, pursuant to 12 CFR
Sec. 41.90 of the FACT Act:
a. assign specific responsibility for the implementation of the
Procedures; review annual reports prepared by staff regarding
Utilities compliance with the provisions of the FACT Act;
4. Having Utilities staff coordinate the data security provisions of the
Procedures with the Information Technology Department’s
requirements for the Information Security Policy and Information
Privacy Policy;
5. Train staff, as necessary, to effectively implement the Procedures;
6. Exercise appropriate and effective oversight of service provider
arrangements; and
7. Approve material changes to the Procedures as necessary to
address changing identity and credit theft risk (Section 6(a) (3)).
If actual physical or electronic theft of customer identity or credit occurs, the Directors
of the Utilities, Information Technology, and Administrative Services Departments shall
work with the City Manager’s Office, City Attorney, City Auditor and the Palo Alto Police
Department, as appropriate, to mitigate the threat.
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Proposed Effective Date: February 8, 2016
4. Customer Identity and Credit Information, Systems and Access
A. Classification of Information
1. Customer Identity Information
Customer identity and credit information subject to theft includes name,
address, account number, Social Security Number, spouse or secondary account
holder identification, contact information, credit information, log-ins and
passwords.
2. Customer Financial Information
Customer financial information subject to theft includes payment history,
deposit information, payment transaction records, extended payment
arrangements, credit card numbers, voided check information, and bank account
numbers.
B. Utilities Customer Information Systems
1. Historical Customer Identification and Financial Information
Current and prior customer information resides in BANNER, the CPAU
predecessor to SAP. This database has been retained for archival
purposes, and this information could be subject to theft.
2. SAP Utilities Customer Care and E-Services
On May 4, 2009, the City implemented a new SAP-based Utilities
Customer Care and Service (U-CCS) information system. In March of
2010, the Utilities Customer E-Service (UCES) system with the “My
Utilities Account” (MUA) web portal was activated. Confidential Utilities
Customer information is retained in the U-CCS and Utilities Customer E-
Service (U-CES) online information system, and this information could be
subject to theft.
Implementation of the U-CCS requires ongoing review and modification
of the business practices, policies and procedures for protecting
consumer identity and credit information in Utilities Customer Service,
Billing and Payment, Credit and Collection, and other City departments.
Cyber-security precautions were created prior and subsequent to the
implementation of the online customer e-service system. Cyber-security
enhancements are also made on an ongoing basis to assure that access to
customer identity and credit data is properly restricted to authorized
staff.
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Proposed Effective Date: February 8, 2016
C. Identity and Credit Information Access
1. Securing Identity and Credit Information within the SAP Utilities Customer Care
and Service (U-CCS) System
a. Unique numbers are used to establish credit, manage customer account
security, identify customers, and permit collection action after
disconnection for non-payment. This information is required under Utilities
Rule and Regulations #4 “Application for Service.” Refusal to provide the
required information will terminate the CPAU “Application for Service”
process.
b. Upon opening, transferring or closing customer accounts, current customer
billing procedures require the applicant (and spouse or secondary account
holder if the account is opened in both names) to provide either
his/her/their Social Security Numbers (SSN) or Driver’s License Numbers
(DLN). For residential customers, if the SSN or DLN is not available, the
identification requirement defaults to the U.S. customer’s passport
number. These numbers will be masked except for the last four digits.
c. For commercial customers, the required identification is the Tax
Identification Numbers (TIN). TINs will be masked except for the last four
digits.
d. City staff access to customer Utilities information will be SAP role-specific,
allowing certain functions within the system to be accessible. Role
assignments will be made based upon review and approval by the SAP
Project Management Office (PMO), the Utilities Department, and the
Administrative Services Department. Financial functions of particular roles
include, but are not limited to: establishment and refund of deposits;
billing adjustments; payment reversals; cancellation of bills; and write-off
of outstanding balances. Roles and responsibilities will be reviewed
quarterly by CPAU management and the PMO, with the intent to limit the
number of staff having access to sensitive customer identity and financial
data.
e. Staff will review documents to ensure that only customer name, and
correct mailing or service address, are displayed in any mail-merged
documents or mailing labels.
f. A bonded, professional shredding company will be retained to destroy all
bulk documents containing customer billing information. Documents
awaiting bulk destruction will be kept in a locked receptacle. Documents
with red flag data, not being held for bulk destruction, will be shredded on-
site, as soon as they are no longer needed by the staff member generating
the documents.
g. All payment and operational transactions within each customer account
will be monitored and tracked by the SAP internal audit function.
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Proposed Effective Date: February 8, 2016
h. Staff roles and authorizations for the unmasking and transmission of
customer Social Security Numbers to the City’s collection agency will be
restricted and monitored.
2. Securing Identity and Credit Information within the SAP Utilities Customer E-
Service (U-CES) System
In order to access account information online, customers must create a user
name and password. These are controlled by the customer, and the Utilities
Customer E-Service (U-CES) account is accessed via the “My Utilities Account”
(MUA) web portal. Customer accessible information includes: the name(s) on
the account, billing and service addresses associated with the account,
consumption data; meter reads; dates of service; charges; billing adjustments;
and payment history. Customers can conduct a limited number of on-line
transactions, including modifying their e-mail addresses, establishing or updating
a phone number, and sending a customer note to CPAU staff regarding account
information. The U-CES system permits the linking of all accounts for the same
customer to a single customer-created user name and password; viewing and
payment of bills online; printing of monthly bills via an online download;
requesting a move-out, online self-enrollment in bank drafting; making single-
transaction credit card payments; communicating with CPAU staff via email, and
reviewing bank draft transactions.
a. Failure by the authorized account-holder to designate alternative parties to
access their account information (spouse, domesticate partner, or other
third-party) will restrict account access to either the customer, or court-
ordered estate executor.
b. The Terms and Conditions and Frequently Asked Questions sections for
cyber-security, customer access, and use of the online My Utilities Account
system will be updated immediately after changes are implemented.
c. Notification of CPAU by the authorized account holder that their identity or
credit information has been compromised or stolen will result in termination
of external online access to the affected account until such time as the
account can be re-established by the customer.
d. A firewall installed to protect the SAP UCES portal “My Utilities Account”
shall be tested and maintained on an on-going basis.
3. Non-Utilities City Staff Access to Customer Red Flag Data
a. Strict role definitions, limiting the potential of access or theft of information
via stolen password or City staff ID, will be maintained. Access to changes to
customer accounts will be limited to the specific roles, reviewed and
authorized quarterly.
b. Individual or department access to Utilities customer account data by non-
Utilities City staff will be reviewed and approved quarterly by the SAP Project
Management Office (PMO) and CPAU management.
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Proposed Effective Date: February 8, 2016
c. Electronic access to selected Utilities customer account data by non-Utilities
City staff will be restricted to non-red flag data fields and tables.
d. Audit trails will be kept for financial transactions within the U-CCS and U-CES
systems and include, but not be limited to, reversed transactions, account
credits and refunds, and physical refund checks.
e. Confidential data included in correspondence submitted to the City shall be
redacted before being made publicly available.
5. Identification, Detection, Response and Mitigation of Red Flags
The “Procedures for Customer Identity and Credit Security” are already in place to
protect customer identity and credit information from theft. Some of the Procedures
that apply are initiated by CPAU staff, while others apply when customers access their
own account information. The “Procedures” are utilized during the opening, access,
billing and collection of payments, and the transfer or closing of customer accounts.
They also apply as customer accounts and associated records are internally accessed.
Any identification, detection or awareness by CPAU of a Red Flag incident would result
in an investigative response and mitigation effort on the part of Utilities, and may
include contact with an appropriate law enforcement agency on behalf of a CPAU
customer, or self-reporting by an existing CPAU customer. CPAU will determine whether
to freeze access to the customer account information, or initiate a review of staff access
of account information to verify the appropriateness of that access.
A. Customer Service
1. Identifying Red Flags
a) To validate the identity of the prospective covered account holder, a
Utilities account will not be opened, changed or closed without
submittal of the Red Flag data required to determine the identity of
the account holder. Customer failure to provide a Social Security
Number, Driver’s License Number, Tax Identification Number, or
Passport Number will terminate the account initiation process.
Utilities Rule and Regulation 4, “Application for Service”
b) Utilities Customer Service, Credit and Collection, and Billing staffs will
include the Procedures for Identity and Credit Security in their
Policies and Procedures.
Utilities Customer Support Services Division Requirement
c) Utilities Customer Service, Credit and Collection, and Billing staffs will
conduct annual training in the Procedures for all staff members.
Utilities Customer Support Services Division Requirement
2. Detecting Red Flags
a) To prevent unauthorized access to a Covered Account, a Utilities
account will be subject to investigation and frozen for transactions in
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Proposed Effective Date: February 8, 2016
the event of presentation of suspicious documents for program
application or discounts, determination of a compromised customer
password, notices from banking institutions of unauthorized charges
to an account, and/or notices from consumer reporting agencies on
customer credit freezes.
City Policy and Procedure 1-35/UTL, “Interim Guidelines and
Procedures for Protecting Confidential Utilities Information”
Utilities Customer Service Requirement
3. Responding to Red Flags
a) Customer reports of identity or credit card theft provided to
Customer Service will be routed to the Palo Alto Police Department’s
Identity Theft Section for completion of the Identity Theft Report
Form. Customers contacting the PAPD to report an incident of
identity or credit card theft will be routed to Customer Service, so
that the customer’s Covered Account Red Flag data can be secured.
Utilities Customer Service Requirement
4. Mitigating Red Flags
a) To prevent unauthorized access to red flag data tables, the SAP query
functions that had allowed CPAU staff access to non-masked
customer confidential data have been disabled.
b) To prevent unauthorized access to red flag data in a covered account,
all electronic “screen shots” of monitor images containing red flag
data submitted to the IT Helpdesk by staff to illustrate account
problems will be stored in a secure electronic folder with staff access
restricted by authorized SAP role.
Business Requirement
SAP Project Management Office (PMO) Requirement
c) Access to the archived BANNER customer information database will
continue to be limited to staff having an authorized SAP role. To
prevent unauthorized access to Red Flag data in an archived Covered
Account, all Red Flag data has been deleted in BANNER (prior Utilities
Customer Information System), including Social Security Numbers
(SSN), and the confidential Customer Notes section has been deleted.
d) Full Encryption of credit card numbers in SAP Production, Testing and
Development environments is required.
Business Requirement
SAP Project Management Office (PMO) Requirement
B. Billing And Payment
Customers may self-report instances of identity or credit theft; notice may
be made by law enforcement agencies of identity or credit theft; inaccurate
information may be provided by customers for bank draft payments of
Utilities bills; reports may be received of compromised internal credit card
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Proposed Effective Date: February 8, 2016
security; reports may be received of compromised internal checking account
(bank draft) security; and reports may be received of compromised external
third-party payment vendor security (reported by customer or vendor).
1. Identifying Red Flags
The Utilities customer credit card information has been encrypted in
conformance with Payment Card Industry (PCI) Standards.
a) Utilities customer credit card information will not be stored on the
same server that houses the portal that customers use to access their
account data.
b) Activation of the "role" for access to the encrypted data table will be
restricted to three Information Technology staff members who are
responsible for data management of the Utilities SAP system, and
who take direction from the PMO (but are not part of the PMO). Once
access to the encrypted data table is approved by the PMO, and then
activated, only an expert programmer familiar with the SAP
programming language and the encryption protocol will be
authorized to decrypt the data. Thus, access to the credit card data
will be protected by three levels of security.
c) For quality control purposes, all access to the table containing the
encrypted data will be continuously monitored and tracked by the
SAP audit function.
d) Utilities customer Social Security Numbers, Tax Identification
Numbers, credit card numbers and expiration and bank drafting
information will be masked on all three CCS and UCES software
production, test, and development platforms.
e) Customers choosing to pay by bank draft will submit voided checks
which are kept in a locked cabinet with access restricted to the
Manager, Customer Service and Meter Reading, and the Customer
Service Specialist-Lead, and maintained in accordance with the City’s
Records Retention Policy.
Business Requirement
SAP Project Management Office (PMO) Requirement
2. Detecting Red Flags
a) Receipts produced for credit card payments only contain the last four
digits of the credit card, and as an added precaution, expiration date
information is not included on the receipt.
City of Palo Alto Cash Handling Procedures
Utilities Customer Service Desk Procedures
3. Responding to Red Flags
Customer Service has worked with the Palo Alto Police Department (PAPD) to
update the existing PAPD Identity Theft Report Form. This update includes
the contact information for CPAU Customer Service and requests the
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Proposed Effective Date: February 8, 2016
individual completing the document to contact CPAU to report the identity
or credit problem, so that the customer’s Utilities account information can be
secured.
a) Incidents of possible customer identity theft shall be reported to the
PAPD within 24 hours.
Utilities Customer Service Requirement
4. Mitigating Red Flags
a) Verification of SAP credit card handling of encrypted storage, masked
display and access tracking will be provided to the City Auditor.
Project Management Office (PMO) Requirement
b) Copies of customer credit card slips (when paid by phone) shall be
shredded, unless mailed to the customer at their request.
c) Customer data printouts, reports, efficiency applications, worksheets,
receipts, and bills generated in the IT Test or Development systems,
will be shredded.
d) To ensure proper security and handling of credit card slips, Customer
Service Phone Center staff will use a keyed lockbox for storage.
e) To secure credit card transactions, the computer terminal used for
credit card transaction payment processing in the Customer Service
Phone Center will be secured so it cannot be viewed by non-
Customer Service staff.
Business Requirement
SAP Project Management Office (PMO) Requirement
C. Credit And Collection
1. Identifying Red Flags
Identification of Red Flag events in the Credit and Collections process will
include:
a) Failure to internally pursue payment of outstanding debt on a
covered account
b) Failure by Collection Agency to pursue outstanding debt on a covered
account
c) Change in billing address for reimbursement of deposits or payment
credits without a change in service address.
Utilities Credit and Collection/Bad Debt Process
2. Mitigating Red Flags
a) Customer security deposits will be manually and electronically
established and tracked.
b) CPAU will continue to recommend residential and commercial
deposits policies to Council which utilize the provisions of the
California Public Utilities Code, allowing each utility to establish
accounts and furnish service based solely upon the creditworthiness
of the applicant as determined by the utility.
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Proposed Effective Date: February 8, 2016
c) CPAU will not utilize commercially available consumer credit reports
to establish deposits. Section 311 of the FACT Act requires a creditor
to provide consumers with a risk-based pricing notice when, based in
whole or in part of the consumer’s credit report, the creditor grants,
extends or otherwise provides credit to the consumer on “material
terms that are materially less favorable than the most favorable
terms it grants to a substantial portion of its other customers.”
Utilities Credit and Collection/Bad Debt Process
D. Other City Departments
1. Identifying Red Flags
a) Other Departments in the City, wishing to have online access to
Utilities customer account information to determine residency, verify
program applicability, determine dates for permitting, etc., will be
restricted in their ability to view customer Red Flag data, and will not
be able to make changes to the data in the system.
2. Detecting Red Flags
a) Other Departments in the City, wishing to have “hard copy” reports of
Utilities customer information will be unable to have printouts
containing customer Red Flag information.
3. Responding to Red Flags
a) Employees of GreenWaste Recovery shall be permitted electronic
access to the Utilities CCS system pursuant to the contract with the
City for solid waste services.
{End}
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Effective Date: November 1, 2010 Page 1 of 14
Proposed Effective Date: February 8, 2016
City of Palo Alto Utilities
DRAFT
2010 2016 Procedures for
Customer Identity and Credit Security
Security
ATTACHMENT B
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Effective Date: November 1, 2010 Page 1 of 14
Proposed Effective Date: February 8, 2016
2010 2016 Procedures for
Customer Identity and Credit Security
SECTION PAGE
1. Policy Statement 3
3
2. Utilities Identity and Credit Theft
Prevention Program 4
A. Definitions 4
B. The Red Flag Rule 4
C. Identity and Credit Theft Program Adoption 5
(Procedures)
D. Requirements of the Procedures 5
3. Administration of the Procedures for Customer
Identity and Credit Security 6
A. Palo Alto City Council 6
B. Director of Utilities 6
C. Executive Leadership Team 6
4. Customer Identity and Credit Information,
Systems and Access 7
A. Classification of Information
B. Utilities Customer Information Systems 7
C. Identity and Credit Information Access 8
5. Identification, Detection, Response and
Mitigation of Red Flags 10
A. Customer Service 10
B. Billing and Payment 11
C. Credit and Collection 13
D. Other City Departments 14
endEnd
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Effective Date: November 1, 2010 Page 1 of 14
Proposed Effective Date: February 8, 2016
1. Policy Statement
The City of Palo Alto shall ensure that proprietary and confidential Utilities customer
information is secure from identity theft as required by law and business practice.
The Fair Credit Reporting Act, 15 United States Code, Section 1681 ETet. seq., was
amended to include the Fair and Accurate Credit Transactions Act of 2003 (Public
Law 108-159), hereinafter referred to as the FACT Act.
The FACT Act requires those businesses and organizations which can affect
consumer credit to create a formal program to detect, prevent, respond and
mitigate potential identity theft before December 31, 2010.
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Effective Date: November 1, 2010 Page 1 of 14
Proposed Effective Date: February 8, 2016
2. Utilities Identity and Credit Theft Prevention Program
The Fair and Accurate Credit Transaction Act of 2003 (FACT Act) requires those
entities which can affect consumer credit to create a formal identity theft
prevention program to detect, prevent and mitigate identity theft before December
31, 2010.
A. Definitions
The “Red Flag Rule” is a set of United States federal regulations that require
certain businesses and organizations identified as “creditors” to develop and
implement documented plans to protect consumers from identity theft.
“Identity theft' means a fraud committed using the identifying information of
another person.
A “creditor” is any entity that regularly extends, renews, or continues credit; any
entity that regularly arranges for the extension, renewal, or continuation of
credit; or any assignee of an original creditor who is involved in the decision to
extend, renew, or continue credit. Accepting credit cards as a form of payment
does not in and of itself make an entity a creditor. Creditors include finance
companies, automobile dealers, mortgage brokers, utility companies, and
telecommunications companies. Where non-profit and government entities
defer payment for goods or services, they, too, are to be considered creditors.
Only those financial institutions and creditors that offer or maintain "covered
accounts" must develop and implement a written Program.
A "covered account" is either: an account primarily for personal, family, or
household purposes; that involves or is designed to permit multiple payments or
transactions, such as a credit card account, mortgage loan, car loan, margin
account, cell phone account, utility account, checking account, or savings
account; or any other account for which there is a reasonably foreseeable risk to
customers or creditor from identity theft.
An “Identity Theft Report” alleges an identity theft; is a copy of an official, valid
report filed by a consumer with an appropriate Federal, State, or local law
enforcement agency, including the United States Postal Inspection Service; and,
subjects the person filing the report to criminal penalties relating to the filing of
false information if, in fact, the information in the report is false.
B. Red Flag Rule
There are a total of twenty-six individual red flags comprising the Red Flag Rule,
with five categories of common red flags:
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1. Alerts, notifications, and warnings from a credit reporting company, including
address discrepancies.
2. Suspicious documents that look like they have been altered or forged, or that
the information or description does not match the applicant or customer.
3. Suspicious personal identifying information, including inconsistent data.
4. Suspicious account activity, including name changes, unauthorized charges or
address changes for credits or refunds.
5. Notification by another source, including a customer, another victim of
identity theft, a law enforcement authority, or other person regarding an
account having an Identity heft Report completed, or other notice that an
account may have been compromised by identity theft.
C. Identity and Credit Theft Prevention Program Adoption (the Procedures)
The City Council of Palo Alto adopted the Utilities Department formal identity
and credit theft prevention program entitled , the “Procedures for Customer
Credit Security” (Procedures) on September 3, 2008. The Procedures focus on
red flags - defined as patterns, practices, or specific activities that indicate
possible existence of identity theft on a covered account.
On September 2, 2009, Staff provided the Utilities Advisory Commission (UAC)
with a summary of red flag events that occurred during the prior twelve month
reporting period, and proposed 2009 updates to the original 2008 Procedures.
The UAC recommended that the Council approve the proposed changes to the
2008 Procedures. Council approved the 2009 changes on October 5, 2009 (CMR:
390:09).
D. Requirements of the Procedures
The Procedures were designed to:
1. Identify red flags for covered accounts and incorporate those red flags into
the programProcedures
2. Detect red flags that have been incorporated into the Procedures
3. Respond appropriately to any red flags that are detected
4. Mitigate the occurrence of identity or credit theft
5. Ensure the Procedures are updated annually, to reflect the changes in
identity or credit theft risk
6. Provide for administration and update of the Procedures with red flags
identified and incorporated into specific operational and transactional
policies and procedures for City departments with access to confidential
Utilities customer data.
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3. Administration of the Identity and Credit Theft Procedures for
Customer Identity and Credit Security
A. Palo Alto City Council
The City Council shall review the “Procedures for Identity and Credit Security”
(Procedures) annually, and adopt appropriate changes to meet the requirements
of the FACT Act.
B. Director of Utilities
The Director of Utilities shall oversee implementation of the Procedures in
conformance with the FACT Act. Implementation of the Procedures will provide
for specific responsibility of oversight, reports, and material changes to the
Procedures.
The Director shall submit an annual report to the Utilities Advisory Commission
and City Council providing an update on the identification, detection, response
and mitigation of Red Flag issues occurring during the reporting period, and
recommending the business, organizational, and security changes to the Council
needed to keep the Procedures current. Recommended changes to the
Procedures shall be based on experience with identification, detection,
prevention and mitigation of identity and credit theft; changes in types of
customer accounts offered; and, changes in business practices.
C.A. Executive Leadership Team
The Palo Alto City Council shall provide for the continued administration of the
Procedures. This includes:
1. Approval of the initial written Procedures by Council;
2. Designating the City Manager as Administrator for oversight, development,
implementation and administration of the Procedures;
3. As Administrator for the Procedures, the City Manager shall, pursuant to 12 CFR
Sec. 41.90 of the FACT Act:
a. assign specific responsibility for the implementation of the Procedures;
b. review annual reports prepared by staff regarding Utilities compliance
with the provisions of the FACT Act;
c. have Utilities staff coordinate the data security provisions of the
Procedures with the Information Technology Department’s requirements
for the Information Security Policy and Information Privacy Policy.
d. train staff, as necessary, to effectively implement the Procedures;
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e. exercise appropriate and effective oversight of service provider
arrangements; and
f. approve material changes to the Procedures as necessary to address
changing identity and credit theft risk (Section 6(a)(3)).
If potential or actual physical or electronic theft of customer identity or credit occurs,
the Directors of the Utilities, Information Technology, and Administrative Services, and
Public Works Departments shall work with the City Manager’s Office, City Attorney, City
Auditor and the Palo Alto Police Department, as appropriate, to mitigate the threat.
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4. Customer Identity and Credit Information, Systems and Access
A. Classification of Information
1. Customer Identity Information
Customer identity and credit information subject to theft includes name,
address, account number, Social Security Number, spouse or secondary account
holder identification, contact information, credit information, log-ins and
passwords.
2. Customer Financial Information
Customer financial information subject to theft includes payment history,
deposit information, payment transaction records, extended payment
arrangements, credit card numbers, voided check information, and bank account
numbers.
B. Utilities Customer Information Systems
1. Historical Customer Identification and Financial Information
Current and prior customer information resides in BANNER, the CPAU
predecessor to SAP. This database has been retained for archival
purposes, and this information could be subject to theft.
2. SAP Utilities Customer Care and E-Services
On May 4, 2009, the City implemented a new SAP-based Utilities
Customer Care and Service (U-CCS) information system. In March of
2010, the Utilities Customer E-Service (UCES) system with the “My
Utilities Account” (MUA) web portal was activated. Confidential Utilities
Customer information is retained in the U-CCS and Utilities Customer E-
Service (U-CES) online information system, and this information could be
subject to theft.
Implementation of the U-CCS requires ongoing review and modification
of the business practices, policies and procedures for protecting
consumer identity and credit information in Utilities Customer Service,
Billing and Payment, Credit and Collection, and other City departments.
Cyber-security precautions were created prior and subsequent to the
implementation of the online customer e-service system. Cyber-security
enhancements are also made on an ongoing basis to assure that access to
customer identity and credit data is properly restricted to authorized
staff.
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C. Identity and Credit Information Access
1. Securing Identity and Credit Information within the SAP Utilities Customer Care
and Service (U-CCS) System
a. Unique numbers are used to establish credit, manage customer
account security, identify customers, and permit collection action after
disconnection for non-payment. This information is required under
Utilities Rule and Regulations #4 “Application for Service.” Refusal to
provide the required information will terminate the CPAU “Application
for Service” process.
a. b.Upon opening, transferring or closing customer accounts, current
customer billing procedures require the applicant (and spouse or secondary
account holder if the account is opened in both names) to provide either
his/her/their Social Security Numbers (SSN) or Driver’s License Numbers
(DLN). For residential customers, if the SSN or DLN is not available, the
identification requirement defaults to the U.S. customer’s passport number.
These numbers will be masked except for the last four digits.
b. c.For commercial customers, the required identification is the Tax
Identification Numbers (TIN). TINs will be masked except for the last four
digits.
c. d.City staff access to customer Utilities information will be SAP role-
specific, allowing certain functions within the system to be accessible. Role
assignments will be made based upon review and approval by the SAP
Project Management Office (PMO), the Utilities Department, and the
Administrative Services Department. Financial functions of particular roles
include, but are not limited to: establishment and refund of deposits; billing
adjustments; payment reversals; cancellation of bills; and write-off of
outstanding balances. Roles and responsibilities will be reviewed quarterly by
CPAU management and the PMO, with the intent to limit the number of staff
having access to sensitive customer identity and financial data.
d. e.Staff will review documents to ensure that only customer name, and
correct mailing or service address, are displayed in any mail-merged
documents or mailing labels.
e. f.A bonded, professional shredding company will be retained to destroy
all bulk documents containing customer billing information. Documents
awaiting bulk destruction will be kept in a locked receptacle. Documents with
red flag data, not being held for bulk destruction, will be shredded on-site, as
soon as they are no longer needed by the staff member generating the
documents.
f. g.All payment and operational transactions within each customer account
will be monitored and tracked by the SAP internal audit function.
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g. h.Staff roles and authorizations for the unmasking and transmission of
customer Social Security Numbers to the City’s collection agency will be
restricted and monitored.
2. Securing Identity and Credit Information within the SAP Utilities Customer E-
Service (U-CES) System
In order to access account information online, customers must create a user
name and password. These are controlled by the customer, and the Utilities
Customer E-Service (U-CES) account is accessed via the “My Utilities Account”
(MUA) web portal. Customer accessible information includes: the name(s) on
the account, billing and service addresses associated with the account,
consumption data; meter reads; dates of service; charges; billing adjustments;
and payment history. Customers can conduct a limited number of on-line
transactions, including modifying their e-mail addresses, establishing or updating
a phone number, and sending a customer note to CPAU staff regarding account
information. The U-CES system permits the linking of all accounts for the same
customer to a single customer-created user name and password; viewing and
payment of bills online; printing of monthly bills via an online download;
requesting a move-out, online self-enrollment in bank drafting; making single-
transaction credit card payments; communicating with CPAU staff via email, and
reviewing bank draft transactions.
a. Failure by the authorized account-holder to designate alternative parties to
access their account information (spouse, domesticate partner, or other
third-party) will restrict account access to either the customer, or court-
ordered estate executor.
b. The Terms and Conditions and Frequently Asked Questions sections for
cyber-security, customer access, and use of the online My Utilities Account
system will be updated immediately after changes are implemented.
c. Notification of CPAU by the authorized account holder that their identity or
credit information has been compromised or stolen will result in termination
of external online access to the affected account until such time as the
account can be re-established by the customer.
d. A firewall installed to protect the SAP UCES portal “My Utilities Account”
shall be tested and maintained on an on-going basis.
3. Non-Utilities City Staff Access to Customer Red Flag Data
a. Strict role definitions, limiting the potential of access or theft of information
via stolen password or City staff ID, will be maintained. Access to changes to
customer accounts will be limited to the specific roles, reviewed and
authorized quarterly.
b. Individual or department access to Utilities customer account data by non-
Utilities City staff will be reviewed and approved quarterly by the SAP Project
Management Office (PMO) and CPAU management.
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c. Electronic access to selected Utilities customer account data by non-Utilities
City staff will be restricted to non-red flag data fields and tables.
d. Audit trails will be kept for financial transactions within the U-CCS and U-CES
systems and include, but not be limited to, reversed transactions, account
credits and refunds, and physical refund checks.
e. Confidential data included in correspondence submitted to the City shall be
redacted before being made publicly available.
5. Identification, Detection, Response and Mitigation of Red Flags
The 2009 “Procedures for Customer Identity and Credit Security” are already in place to
protect customer identity and credit information from theft. Some of the Procedures
that apply are initiated by CPAU staff, while others apply when customers access their
own account information. The “Procedures” are utilized during the opening, access,
billing and collection of payments, and the transfer or closing of customer accounts.
They also apply as customer accounts and associated records are internally accessed.
Any identification, detection or awareness by CPAU of a Red Flag incident would result
in an investigative response and mitigation effort on the part of Utilities, and may
include contact with an appropriate law enforcement agency on behalf of a CPAU
customer, or self-reporting by an existing CPAU customer. CPAU will determine whether
to freeze access to the customer account information, or initiate a review of staff access
of account information to verify the appropriateness of that access.
A. Customer Service
1. Identifying Red Flags
a) To validate the identity of the prospective covered account holder, a
Utilities account will not be opened, changed or closed without
submittal of the Red Flag data required to determine the identity of
the account holder. Customer failure to provide a Social Security
Number, Driver’s License Number, Tax Identification Number, or
Passport Number will terminate the account initiation process.
Utilities Rule and Regulation 4, “Application for Service”
b) Utilities Customer Service, Credit and Collection, and Billing staffs will
include the Procedures for Identity and Credit Security in their
Policies and Procedures.
Utilities Customer Support Services Division Requirement
c) Utilities Customer Service, Credit and Collection, and Billing staffs will
conduct annual training in the Procedures for all staff members.
Utilities Customer Support Services Division Requirement
2. Detecting Red Flags
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a) To prevent unauthorized access to a Covered Account, a Utilities
account will be subject to investigation and frozen for transactions in
the event of presentation of suspicious documents for program
application or discounts, determination of a compromised customer
password, notices from banking institutions of unauthorized charges
to an account, and/or notices from consumer reporting agencies on
customer credit freezes.
City Policy and Procedure 1-35/UTL, “Interim Guidelines and
Procedures for Protecting Confidential Utilities Information”
Utilities Customer Service Requirement
3. Responding to Red Flags
a) Customer reports of identity or credit card theft provided to
Customer Service will be routed to the Palo Alto Police Department’s
Identity Theft Section for completion of the Identity Theft Report
Form. Customers contacting the PAPD to report an incident of
identity or credit card theft will be routed to Customer Service, so
that the customer’s Covered Account Red Flag data can be secured.
Utilities Customer Service Requirement
4. Mitigating Red Flags
a) To prevent unauthorized access to red flag data tables, the SAP query
functions that had allowed CPAU staff access to non-masked
customer confidential data have been disabled.
b) To prevent unauthorized access to red flag data in a covered account,
all electronic “screen shots” of monitor images containing red flag
data submitted to the IT Helpdesk by staff to illustrate account
problems will be stored in a secure electronic folder with staff access
restricted by authorized SAP role.
Business Requirement
SAP Project Management Office (PMO) Requirement
c) Access to the archived BANNER customer information database will
continue to be limited to staff having an authorized SAP role. To
prevent unauthorized access to Red Flag data in an archived Covered
Account, all Red Flag data has been deleted in BANNER (prior Utilities
Customer Information System), including Social Security Numbers
(SSN), and the confidential Customer Notes section has been deleted.
d) Full Encryption of credit card numbers in SAP Production, Testing and
Development environments is required.
Business Requirement
SAP Project Management Office (PMO) Requirement
B. Billing And Payment
Customers may self-report instances of identity or credit theft; notice may
be made by law enforcement agencies of identity or credit theft; inaccurate
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information may be provided by customers for bank draft payments of
Utilities bills; reports may be received of compromised internal credit card
security; reports may be received of compromised internal checking account
(bank draft) security; and reports may be received of compromised external
third-party payment vendor security (reported by customer or vendor).
1. Identifying Red Flags
The Utilities customer credit card information has been encrypted in
conformance with Payment Card Industry (PCI) Standards.
a) Utilities customer credit card information will not be stored on the
same server that houses the portal that customers use to access their
account data.
b) Activation of the "role" for access to the encrypted data table will be
restricted to three Information Technology staff members who are
responsible for data management of the Utilities SAP system, and
who take direction from the PMO (but are not part of the PMO). Once
access to the encrypted data table is approved by the PMO, and then
activated, only an expert programmer familiar with the SAP
programming language and the encryption protocol will be
authorized to decrypt the data. Thus, access to the credit card data
will be protected by three levels of security.
c) For quality control purposes, all access to the table containing the
encrypted data will be continuously monitored and tracked by the
SAP audit function.
d) Utilities customer Social Security Numbers, Tax Identification
Numbers, credit card numbers and expiration and bank drafting
information will be masked on all three CCS and UCES software
production, test, and development platforms.
e) Customers choosing to pay by bank draft will submit voided checks
which are kept in a locked cabinet with access restricted to the
Manager, Customer Service and Meter Reading, and the Customer
Service Specialist-Lead, and maintained in accordance with the City’s
Records Retention Policy.
Business Requirement
SAP Project Management Office (PMO) Requirement
2. Detecting Red Flags
a) Receipts produced for credit card payments only contain the last four
digits of the credit card, and as an added precaution, expiration date
information is not included on the receipt.
City of Palo Alto Cash Handling Procedures
Utilities Customer Service Desk Procedures
3. Responding to Red Flags
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Customer Service has worked with the Palo Alto Police Department (PAPD) to
update the existing PAPD Identity Theft Report Form. This update includes
the contact information for CPAU Customer Service and requests the
individual completing the document to contact CPAU to report the identity
or credit problem, so that the customer’s Utilities account information can be
secured.
a) Incidents of possible customer identity theft shall be reported to the PAPD
within 24 hours.
Utilities Customer Service Requirement
4. Mitigating Red Flags
a) Verification of SAP credit card handling of encrypted storage, masked
display and access tracking will be provided to the City Auditor.
Project Management Office (PMO) Requirement
b) Copies of customer credit card slips (when paid by phone) shall be
shredded, unless mailed to the customer at their request.
c) Customer data printouts, reports, efficiency applications, worksheets,
receipts, and bills generated in the IT Test or Development systems, will
be shredded.
d) To ensure proper security and handling of credit card slips, Customer
Service Phone Center staff will use a keyed lockbox for storage.
e) To secure credit card transactions, the computer terminal used for credit
card transaction payment processing in the Customer Service Phone
Center will be secured so it cannot be viewed by non-Customer Service
staff.
Business Requirement
SAP Project Management Office (PMO) Requirement
C. Credit And Collection
1. Identifying Red Flags
Identification of Red Flag events in the Credit and Collections process will
include:
a) Failure to internally pursue payment of outstanding debt on a
covered account
b) Failure by Collection Agency to pursue outstanding debt on a covered
account
c) Change in billing address for reimbursement of deposits or payment
credits without a change in service address.
Utilities Credit and Collection/Bad Debt Process
2. Mitigating Red Flags
a) Customer security deposits will be manually and electronically
established and tracked.
b) CPAU will continue to recommend residential and commercial
deposits policies to Council which utilize the provisions of the
California Public Utilities Code, allowing each utility to establish
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accounts and furnish service based solely upon the creditworthiness
of the applicant as determined by the utility.
c) CPAU will not utilize commercially available consumer credit reports
to establish deposits. Section 311 of the FACT Act requires a creditor
to provide consumers with a risk-based pricing notice when, based in
whole or in part of the consumer’s credit report, the creditor grants,
extends or otherwise provides credit to the consumer on “material
terms that are materially less favorable than the most favorable
terms it grants to a substantial portion of its other customers.”
Utilities Credit and Collection/Bad Debt ProceduresProcess
D. Other City Departments
1. Identifying Red Flags
a) Other Departments in the City, wishing to have online access to
Utilities customer account information to determine residency, verify
program applicability, determine dates for permitting, etc., will be
restricted in their ability to view customer Red Flag data, and will not
be able to make changes to the data in the system.
2. Detecting Red Flags
a) Other Departments in the City, wishing to have “hard copy” reports of
Utilities customer information will be unable to have printouts
containing customer Red Flag information.
3. Responding to Red Flags
a) Employees of GreenWaste Recovery shall be permitted electronic
access to the Utilities CCS system pursuant to the contract with the
City for solid waste services.
{Eend}
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NOT YET APPROVED
160114 jb 6053669
Resolution No. _____
Resolution of the Council of the City of Palo Alto
Approving the City of Palo Alto Utilities
2016 Procedures for Customer Identity and Credit Security
R E C I T A L S
A. Federal Trade Commission (FTC) regulations under the Fair and Accurate Credit
Transactions Act (FACT Act) of 2003 require entities which can affect consumer credit to create
a Security program to detect, prevent, and mitigate identity theft.
B. A public utility such as the City of Palo Alto Utilities is considered such an entity
because it offers or maintains a type of consumer account covered under the FACT Act.
C. Council adopted the City of Palo Alto Utilities original “Procedures for Customer
Credit Security” (Procedures) via Resolution No. 8857 on September 15, 2008.
D. There have not been any verified instances of Utilities customer identity or credit
theft since the adoption of the 2010 Procedures.
NOW, THEREFORE, the Council of the City of Palo Alto RESOLVES as follows:
SECTION 1. The Council hereby adopts the City of Palo Alto Utilities “2016 Procedures
for Customer Identity and Credit Security.”
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ATTACHMENT C
NOT YET APPROVED
160114 jb 6053669
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 environmental assessment is required.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
__________________________ _____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
___________________________
Deputy City Attorney
_____________________________
City Manager
_____________________________
Director of Utilities
_____________________________
Director of Administrative Services