Policy:

In order to detect, prevent and mitigate identity theft, the following procedures will be followed in keeping with the Federal Trade Commission (FTC) “Red Flag Rules” regulation of the Fair and Accurate Credit Transactions Act (72 FR63718, Sections 114 and 135).  A Red Flag is a pattern, practice or specific activity that indicates possible identity theft.  Red Flags include:

• Name discrepancies
• Address discrepancies
• Presentation of suspicious identification or other documents that may have been altered or forged
• Photograph on identification documents that do not match the appearance of the person presenting the documents
• Notification from student, employee or a service provider that a security breach may have occurred

Instances of suspected identity theft must be reported immediately to the Registrar and to the Director, Student and Alumni Services for full investigation.  This Identity Theft Prevention policy will be reviewed/revised at least every four years.

Procedures:

     Detection:

1. Application to the Nursing Program requires the applicant’s full name.  Names on all supporting materials (transcripts, certificates, test scores, financial aid applications) must match names on application. In cases where names do not match, the applicant will be requested to provide verification (marriage license, court record of name change).

2.  Official transcripts from previously attended high schools and colleges are required as part of the application to the Nursing Program.

3.   International students are required to send official transcripts from foreign schools to an approved documentation service for translation and verification. Prior education assessment reports are sent directly from the translation service company to the Admissions Office.

4. International students must present original documents related to their legal status within the United States and must keep the Student and Alumni Affairs Coordinator appraised of any change in status.  The Director, Student and Alumni Services and the Student and Alumni Affairs Coordinator are trained to detect document forgery and alteration.

5. All students must have a CORI check prior to clinical nursing courses. A photo identification is required to be viewed and verified by a designated school official in the presence of the student as part of the CORI application process.  Positive CORI results are reviewed by the Vice President for Education with consultation from Hallmark Health Human Resources Department as needed.  Clarifying documentation may be required from the student prior to clinical experiences and may prevent clinical attendance.

6.   Registered Nurse Faculty and LPN applicants will have the validity and currency of professional licenses verified on-line via the Massachusetts Board of Registration in Nursing website (See RN and CPR certification verification policy).

     Prevention:

1. All students are required to complete a student information form at the start of each semester to insure information is current including name, address, telephone number, cell phone number with cell service provider, and e-mail.  This information is updated each semester in the student database system.
 
2. Student academic, financial and health records are maintained in locked files in the offices of the Registrar, Financial Aid Coordinator and Student and Alumni Affairs Coordinator.  Access to student records is limited to those who require access in the performance of job responsibilities per the Student Record policy.  Offices and files are locked when offices are not attended.

3. Access to the web based student management database is limited to administrators, faculty and staff whose job responsibilities require access.  Access is further restricted by individual password protection.

4. The student management database is hosted at a secure off site facility through a contracted service provider.  Details of the data base security protection are included in the vendor contract located in the office of the Director, Student and Alumni Services.

5. Student identification numbers are randomly assigned by the student management database system.  Social security numbers are not used as identification numbers and are classified as non-directory student data.

6. Service providers involved in billing and collection of tuition and loans must have written security processes that comply with federal government requirements including the “Red Flag Rules.”  The only information that is shared with service providers is information required to perform credit checks, perform address searches and properly bill and collect payments.  Such student information includes student name, address, telephone numbers, social security number and date of birth.

7. Administrators, faculty and staff whose job responsibilities require access to student/employee records are trained in Family Educational Rights and Privacy Act (FERPA) and no student/employee information is provided to others without documented permission of the student unless compelled by law.

     Mitigation:

1. Reports of suspected identity theft will be investigated by the Director, Student and Alumni Services to determine if there has been a security breach.

2.   If a breach is detected, action will be taken to prevent further identity theft breaches.  The targeted student/employee will be notified of the breach.  Additional actions may be taken including disciplinary actions and notification of the attempted fraud to law enforcement.