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FTC's New Red Flags Rules FAQ

Today the US FTC released "Frequently Asked Questions: Identity Theft Red Flags and Address Discrepancies."

Here are a couple important things to take away from this FAQ...

Who is the FAQ prepared for?

It was created for all entities that must follow the Red Flags Rules; to "assist financial institutions, creditors, users of consumer reports, and card issuers in complying with the final rulemaking on Identity Theft Red Flags and Address Discrepancies implementing section 114 of the Fair and Accurate Credit Transactions Act of 2003 (FACT Act)." Note that many/most healthcare providers fall under the Red Flags Rules.


What is "identifying information"?

"The FTC defines the term "identifying information" to mean: any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including any- 1) Name, social security number, date of birth, official State or government issued driver's license or identification number, alien registration number, government passport number, employer or taxpayer identification number; 2) Unique biometric data, such as fingerprint, voice print, retina or iris image, or other unique physical representation; 3) Unique electronic identification number, address, or routing code; or 4) Telecommunication identifying information or access device (as defined in 18 U.S.C. ยง 1029(e))."

If you think you MIGHT be a covered entity under the Red Flags Rule, READ THIS FAQ!

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Rebecca Herold's Bio:

Rebecca Herold, CISSP, CIPP, CISM, CISA, FLMI, has been providing information security, privacy and regulatory assistance and services to organizations from a wide range of industries for the past two decades. Rebecca was instrumental in building the information security and privacy program while at Principal Financial Group, which was awarded the CSI Information Security Program of the Year Award in 1998. IT Security ranked Rebecca as one of the top 59 IT security influencers, and Computerworld put Rebecca their list of the world's best privacy experts and on their list of the best privacy consulting firms in both 2007 and 2008. Rebecca has been CPO for two consulting organizations, and has had her own information privacy, security and compliance business since 2004. Rebecca has written chapters for several books, dozens of articles, and has been writing a monthly privacy column for the CSI Alert newsletter since the beginning of 2001, and is working on her 13th book. Some of her other books include The Privacy Papers, Managing an Information Security and Privacy Awareness and Training Program, The Definitive Guide to Security Inside the Perimeter (Realtime Publishers), The Shortcut Guide to Improving IT Service Support through ITIL (Realtime Publishers), and The Practical Guide to HIPAA Privacy and Security Compliance. In addition, Rebecca is the leader of The Realtime IT Compliance Community where she posts to her IT Compliance weblog. You can contact Rebecca at: rebecca_herold@realtimepublishers.net.