The Federal Trade Commission's "Red Flags Rule" implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. In follow-up, this policy is intended to implement an Identity Theft Prevention Program for the University that:
warnings ("Red Flags") for certain identified covered accounts
it offers or maintains;
|(ii)||Detects those Red Flags that have been identified;
|(iii)||Responds appropriately to any Red
Flags that are detected to seek to prevent and mitigate identity
||Ensures that the Identity Theft
Prevention Program is reviewed periodically and updated as
appropriate to reflect changes in risks to students and with
regard to the safety and soundness of creditors from identity
||Encourages University employees to
report suspected cases of identity theft involving a covered
account or student to the Vice President for Administration and
Finance or to the University General Counsel's Office.
1. Covered Accounts
"covered account" is an account that is offered or maintained primarily
for personal, family or household purposes that involves or is designed
to permit multiple payment transactions. Wichita State University has
identified five types of covered accounts, four of which are
administered by the University and one that is administered by a service
University covered accounts:
The University Identity Theft Prevention Program identifies the following
for identification appear to have been altered or forged;
|b.||The photograph or physical description on the identification is
not consistent with the appearance of the student presenting the
|c.||A request made from a non-WSU
issued email account;
||A request to mail something to an
address not listed on file; or
||Notice from customers, victims of
identity theft, law enforcement authorities, or other persons
regarding possible identity theft in connection with covered
3. Detection of Red Flags
The University Identity Theft Prevention Program will detect Red Flags
relevant to each type of covered account as follows:
|a.||Refund of credit balances involving
PLUS loans - As directed
by federal regulations (U.S. Department of Education) these
balances are required to be refunded in the parent's name and
mailed to their address on file within the time period
specified. No request is required.
Red Flag - None as this is initiated by the University.
|b.||Refund of credit balances without
PLUS loans - Request from current students must
be made in writing by using the University form "Petition for
Exception to Tuition Refund Policy." If the request is approved,
the refund amount is direct deposited in the student's bank
account using the banking information provided to WSU by the
student using their myWSU ID and the student portal. If direct
deposit is not available, checks can only be mailed to an address
on file, as provided by the student. If an address is determined
to be non-deliverable by the U.S. mail, checks can be picked up in
person by showing their WSU Photo ID.
Red Flag - Photo ID does not appear to be authentic or does not match the appearance of the student presenting it.
||Deferment of tuition payments
(tuition payment plan) - Students request a
tuition payment plan by using their myWSU ID to access the secure
WSU student portal. Requests are made electronically and payment
plans are accepted provided the student has no delinquent charges
on their account.
Red Flag - None, as students can only make this request via the secure portal. In person requests are not accepted.
4. Oversight of Service Provider
The University shall take steps to ensure that the activity of a service
provider is conducted in accordance with reasonable policies and
procedures designed to detect, prevent, and mitigate the risk of identity
theft whenever the organization engages a service provider to perform an
activity in connection with one or more covered accounts.
Currently the University uses ECSI to administer the Perkins Loan
program. Students contact ECSI directly through its website or by
telephone and provide personally identifying information to be matched to
records that Wichita State University has provided ECSI.
5. Staff Training
University employees responsible for implementing the Identity Theft
Prevention Program shall be trained in the detection of Red Flags and the
responsive steps to be taken when a Red Flag is detected. Training shall
be provided on an annual basis.
6. Periodic ReviewThe General Counsel will implement and facilitate an annual review of the University Identity Theft Prevention Program and suggest updates as deemed appropriate or as required by law.
This policy shall be included in the WSU Policies and Procedures Manual and shared with appropriate constituencies of the University.
The Vice President for Administration and Finance shall have primary responsibility for publication, dissemination and distribution of this University policy.
August 1, 2009
October 13, 2009
May 10, 2013