450.000 - Financial

The Board of Trustees delegates to the president or designee the responsibility to have procedures in place regarding financial planning and monitoring of operating and capital budgets, reserves, investments, and transfers. The procedures must outline the conditions of fiscal responsibility for revenue and expenditures and budget preparation. Those responsible for the College resources must adhere to the procedures and be accountable for all decisions. The College shall review and procedures and practices regularly to mitigate financial risk and loss to the College.

450.015 REFUND POLICIES

Overall Policies

Students who officially withdraw through the Registration Office may receive a refund of tuition and certain fees according to the following schedules:

1. For classes that last at least seven weeks and begin the first week of the quarter:

a. 100% —— If the withdrawal occurs during the first five business days of the quarter (Business days are Monday through Friday.)

b. 100% —— If the class begins on the first Friday evening or the first Saturday of the quarter, and withdrawal occurs no later than the close of business on Monday of the second week of classes.

c. 50% —— If the withdrawal occurs between the sixth business day and the 20th calendar day of the quarter.

d. 0% —— If the withdrawal occurs after the 20th calendar day.

2. For classes that do not begin the first week of the quarter, last less than seven weeks, but have more than five class sessions:

a. 100% ——  If the withdrawal occurs before the second class session.

b. 50%  ——  If the withdrawal occurs after the second class session but before the fourth class session.

3. For classes with a total of five class sessions:

a. 100% ——  If the withdrawal occurs before the second class session.

b. 50%  ——  If the withdrawal occurs after the second class session but before the third class session.

4. For classes with a total of three or four class sessions:

a. 100% ——  If the withdrawal occurs before the first class session.

b. 50%  ——  If the withdrawal occurs after the first class session but before the second class session.

c. 0%   ——  All other cases.

5. For classes with a total of one or two class sessions:

a. 100% ——  If the withdrawal occurs before the first class session.

b. 0% ——  All other cases.

6. There is an automatic 100% refund for classes that are canceled by the College.

7. Refunds for students receiving federal Title IV financial aid will be made in accordance with the Federal Return of Title IV Funds Policy. Students receiving institutional aid will be subject to the Clark College Refund Policy as well. Any aid that is not earned must be returned to its source.

8. Payments made with credit cards will be credited back to the card. Payments made with cash will be reimbursed by check to be mailed within five working days. Payments made by check/money order will be reimbursed by check to be mailed within four weeks after the date of payment. Amounts of reimbursement are established by the refund policy; refund amounts of $1.00 or less are retained by the College. Payments made by a sponsoring agency are reimbursed directly to that agency.

9. Students who believe extenuating circumstances justify an exception to the policy may complete a Refund Exception form at the Registration Office. Exceptions may be granted for documented medical reasons or for active duty military reassignments. Requests for exceptions to the refund policy are accepted through the seventh week of the quarter.

10. A separate refund policy applies to classes offered by Basic Skills (Adult Basic Education (ABE)/General Education Development (GED) and English as a Second Language (ESL)) and Continuing Education departments. For more information, see the Basic Skills (Adult Basic Education (ABE)/General Education Development (GED) and English as a Second Language (ESL)) and Continuing Education sections of the class schedule.

11. Refunds for students participating in the STEPP payment plan will be made by check only.

Title IV Funds Policy

Students who receive financial aid are subject to the Federal Return of Title IV Funds Policy. This policy is effective if a student officially or unofficially withdraws from all credits in the payment period. Students who remain enrolled through at least 60 percent of the payment period (quarter) are considered to have earned 100 percent of the aid received and will not owe a repayment of federal Title IV funds. If a student completes at least one course, they will be subject to the Satisfactory Academic Progress Policy, rather than the Federal Return of Title IV Funds Policy. Federal financial aid recipients are subject to both the federal policy for Title IV aid and the Clark College Institutional Refund Policy for institutional aid.

1. A student’s withdrawal date is one of the following:

a. The date the student began the institution’s withdrawal process or officially notified the institution in writing of intent to withdraw.

b. The midpoint of the quarter for a student who leaves without notifying the institution.

c. The student’s last date of attendance at a documented academically related activity.

d. The student’s last date of attendance as reported by their instructor for a student who leaves without notifying the institution.

2. Funds are returned to the following sources in order of priority, as established by Congress:

a. Unsubsidized FFEL Loans.

b. Subsidized FFEL Loans.

c. FFEL PLUS Loans.

d. Federal Pell Grants.

e. Academic Competitiveness Grant

f. Federal SEOG.

g. National SMART Grant

3. There are six basic steps to the formula for calculating the amount of funds that must be returned to the Title IV programs:

a. Determine date of withdrawal and percentage of payment period attended by the student.

b. Calculate amount of Title IV aid earned by the student.

c. Compare amount earned and amounts disbursed to determine amount unearned.

d. If amount earned is greater than amount disbursed, determine late disbursement.

e. If amount earned is less than amount disbursed, determine amount of Title IV aid that must be returned.

f. Calculate portion of funds to be returned by institution and student.

Both Clark College and the student have specific responsibilities under this policy. Students who owe a repayment of Title IV funds must pay or make satisfactory arrangements to pay that obligation before regaining eligibility for additional financial assistance.

Requirements of 34CFR 668.22 are available in the Clark College Financial Aid Office or on the Clark College website at: http://www.clark.edu/enroll/paying-for-college/documents/CC_Refund_Repayment_Policy.pdf.

450.020 BUDGET AND FISCAL CONTROL

The following policies are established to ensure appropriate budget and fiscal control:

1. Expenditures are to be made in the appropriate account and object when incurred and then funds moved if necessary to prevent an over expenditure of a budget object.

2. Deans and directors are responsible for the results of their actions concerning the budget.

3. Those with fiscal responsibility must plan expenditures so that the budget will last through the entire fiscal year.

4. Those with secondary budget approval authority must ensure that funds are available before signing Purchase Requests or Personnel Requests. For example, ascertain that appointment of staff does not exceed budget before signing Personnel Requests.

5. Reports must be read and reviewed monthly by deans and directors. Problems are to be brought to the attention of the appropriate administrator.

6. If the Executive Cabinet approves any type of expenditure, it will ensure estimates are accurate, funds are
available, and that a budget transfer will be made if necessary. The Executive Cabinet also needs information to understand the impact on future budget years of the proposed expenditure.

7. The vice president of administrative services will review the summary budget/expenditure report periodically with the Executive Cabinet, noting any potential problems.

8. Under no circumstances will an over-expenditure or deficit be permitted. If unavoidable expenses creating a deficit are processed, they will be immediately brought to the Executive Cabinet by the responsible administrator to identify a funding source.

450.025 BUDGET CHANGES

Terms

1. Base Budget – The budget that is approved by the Trustees of Clark College each year.

2. Temporary Budget Adjustment – A change in the base budget that is nonrecurring and/or affects the budget for the current fiscal year only.

3. Permanent Base Budget Change – A recurring change in the base budget that affects subsequent fiscal years.

Procedure

All changes to the budget that occur after the base budget has been approved will be identified as to their permanent/temporary nature, and both the current fiscal year impact and the future year impact (for permanent changes) will be specified.

The Budget Change Request form is to be used to communicate changes in budget to the director of business services and serves as back-up/history for substantiation of changes that have been made.

When budget worksheets are distributed to commence work on the subsequent year's budget, the current year's budget will represent the base budget as approved by the Board for that year, plus all permanent base budget changes that have been approved up to that time.

Approval

Temporary budget adjustments require the approval of appropriate vice president or executive dean (or designee) administratively responsible for the budget.

450.030 CHECKING ACCOUNTS – DEPOSITS OF COLLEGE FUNDS

All funds pertaining to College or College-sponsored programs must be deposited through the College.  Separate checking accounts are not permitted.

All matters associated with banking must be referred to the director of business services.

450.033 INVESTMENT POLICY

It is the policy of ClarkCollege to invest its cash assets in only those investment instruments allowed by the investment policy published by the Office of the State Treasurer so that all liquidity needs are met and annual yields are maximized. The vice president of administrative services is responsible for all investment decisions. Only approved WashingtonState licensed investment dealers will be used to buy and sell investments; all rules published by the Office of the State Treasurer will be followed.

All cash resources will be invested. Investment terms will vary from overnight to one year, depending upon the stability of the cash balance and the annual cycle of cash liquidity needs. Cash and spending plans will be coordinated by the director of business services and the vice president of administrative services to ensure that investment decisions are consistent with long-term spending plans for discretionary funds.

The fiscal analyst, reporting to the director of business services, is responsible for identifying the investable funds and characterizing them as to maturity. The fiscal analyst will also investigate and recommend allowable instruments to the vice president of administrative services. The investment plan will be presented semi-annually to the vice president of administrative services for approval and to the Executive Cabinet at the discretion of the vice president of administrative services. Monthly reports will be prepared by the fiscal analyst for the director of business services and vice president of administrative services, showing the holdings in and the performance of the portfolio.

450.035 CASH CONTROL AND ACCOUNTABILITY

The following guidelines apply to the collection/receipt of money at College locations other than the Cashier's Office:

  1. One person should be designated by the department supervisor as having direct accountability for the money.

  2. Money (cash, checks, money orders, credit card transaction slips, etc.) should be processed/handled in a secure area and kept in a locked/secure place at all times.

  3. To the extent possible, checks and money orders are preferred modes of payment, rather than cash.

  4. No personal checks may be cashed.

  5. No third party checks may be accepted.

  6. Checks must be made payable only to Clark College and must be restrictively endorsed "Clark College--for deposit only" immediately upon receipt.

  7. Credit Cards may only be accepted if a terminal is available. Credit Card numbers are not to be written down to be entered later. It is against Payment Card Industry Compliance regulations to record a cardholder’s credit card number in any form. If a credit card payment is desired and no terminal is available, the payment can only be taken by the Cashier’s Office over the phone or in person where College employees can enter the credit card number directly into a terminal and avoid having a record of the number.

  8. Incoming money must be recorded as soon as possible. Blank form receipts should not be used. All payments received need to be documented by sequentially pre-numbered official receipts or an automated cashiering system. All receipts are to be strictly accounted for and the reason for any missing documents determined and documented.

  9. Receipts are to indicate method of payment (cash, check, etc.), amount of payment, date, preparer, and brief description of basis for payment received. The total dollar amount recorded on the Cash Receipt forms, by method of payment, is to be balanced to the total cash, checks, etc., collected. Overages or shortages are to be reconciled and corrected.

  10. No funds are to be paid to vendors out of deposit cash. Deposits must be intact and must total all monies collected. All disbursements are to be made by Accounting Services following established procedures.

  11. Payments received must be recorded and reconciled to deposits.

  12. A daily sales summary form showing total receipts, payments, overages/shortages, and department account codes must be sent with the deposit. The department must keep a copy of the daily sales form, receipts, and deposit slip for six years, after which they can be destroyed.

  13. It is highly recommended that there be a segregation of duties between the person making up the deposit and the person reconciling to the deposited funds. Individuals handling money should be assigned duties that are complementary to, or checked by, another individual.

  14. Deposits must be made on a daily basis to the Cashier’s Office in Gaiser Hall. Money should not be sent through regular internal campus mail. The Security Department will transport funds to the cashier daily. However, armored transport collects deposits for a small number of departments (Cashier, Bookstore, Culinary Arts, etc.) and transports the deposits to the bank.

  15. "Bank" bags are to be used for transporting money to the cashier. These bags must be locked when being transported. Empty bags will be picked up by Security and delivered back to the department.

  16. Any loss of cash/checks/etc. must be brought immediately to the attention of Security and the vice president of administrative services per Clark College Administrative Procedure 527.035 STOLEN OR LOST ITEMS.

Procedures for the collection/receipt of money at College locations other than the Cashier’s Office must be in written form, reviewed by the internal auditor, and approved by the director of business services in advance. The collection/receipt of cash is restricted to a limited number of locations or departments. Prior approval must be obtained before cash may be accepted at a location other than the Cashier’s Office.

Revised Policy/Procedure Approved by Executive Cabinet
May 8, 2012

450.038 INTERNAL AUDIT

The Internal Audit Office conducts risk and internal control evaluations to help ensure compliance with established accounting procedures, state statutes and regulations, and College policies and procedures.

The internal auditor, in cooperation with administrators and managers:

  1. Reviews and appraises the adequacy and effectiveness of procedural controls over revenues, expenditures, assets, liabilities, and business principles;

  2. Reviews practices of individual employees and units for conformance to established policy;

  3. Reviews accuracy of accounting records;

  4. Reviews audit files, policy statements, regulatory directives, state and federal requirements, and other operating guidelines;

  5. Analyzes records and reports in accordance with auditing procedures and standards to compare performance with requirements;

  6. Reviews audit conclusions and recommendations with responsible administrator or manager;

  7. Prepares written reports regarding analyses and findings;

  8. Develops and updates written policies and procedures related to practices subject to audit;

  9. Evaluates the efficiency of operations when included in scope of audit.

450.040 RENTAL EXPENSE PAYMENTS

For facilities procured by the Office of Instruction, the Office of Instruction will initiate payment of rental expenses as follows:

  1. Prepare a Purchase Request for each facility to encumber approximate dollars needed.

  2. Prepare Invoice Voucher(s) after rental occurs to initiate payment, denoting the appropriate Purchase Order number.

450.045 ANNUAL BUDGET PREPARATION

The operating budget for the College is prepared each year with the following time lines and division of responsibilities:

September

Strategic Priorities affirmed by Executive Cabinet.

President’s draft goals presented to the Board of Trustees.

October

New Goal and Budget Development Packet distributed.

Planning process communicated to the College through e-mail, Clark 24/7, College memos, Clark College Council, Faculty Senate, President’s Dialogue, VPI Forum.

January

New Goal and Budget Development Request forms due to dean or supervisor.

February

Base budget adjustments review forms distributed by Budget Development Office.

Goal and Budget Development Request forms to vice presidents/executive deans.

March

Base budget review returned to Budget Development Office.

Final Goal and Budget Development Requests prioritized within institutional areas.

April

Base budget adjustments and updated base completed.

Final goals are established at Executive Cabinet Work Session.

Final budget prioritization at Executive Cabinet Work Session.

SBCTC funding projections released.

Budget updated to include mandated changes, reconciled base, and funds now available.

May

Board of Trustees Work Session goals.

Draft budget presentation to the Board of Trustees at May Board meeting.

June

Final budget and goals approved by the Board of Trustees.

450.050 TRANSFERS/CORRECTIONS OF EXPENDITURES AND REVENUES

Transfers or accounting adjustments should not be confused with budget changes. (See Administrative Procedure 450.025 BUDGET CHANGES.) Transfers are used to correct coding errors, move funds from one accounting division to another, effect interdepartmental charges, and distribute expenses. Transfers require the approval of the appropriate vice president or executive dean (or designee); a form for that purpose is available on the College Intranet under “Accounting and Business Forms” or from Accounting Services. The fiscal analyst in Accounting Services assists with transfers.

450.065 SERVICE AND ACTIVITY (S & A) FEE BUDGET PREPARATION

The annual budget for the use of service and activity fees, as prescribed in RCW 28B.15.045, shall include the following groups and responsibilities (under the current College committee structure, the Finance Committee for the ASCC serves as the S & A Fee Committee):

1. S & A Fee Committee

a. Students must be the majority of voting membership.

b. The student members must represent diverse student interests.

c. The student members must be recommended by the student government association.

d. The chair is the ASCC finance director.

e. The Committee will present at a public meeting an opportunity for all viewpoints to be heard on funding of student programs and activities.

f. The Committee will evaluate existing and proposed programs and submit budget recommendations with supporting documents simultaneously to the Board and the administration.

2. The Administration

a. Review the recommendations of the S & A Fee Committee.

b. Publish a written response to the S & A Fee Committee outlining potential areas of difference in a timely manner.

c. Meet with the S & A Fee Committee in a good faith effort to resolve any disputes on the recommended budget.

3. The Board of Trustees

a. Receive the budget recommendations from the S & A Fee Committee.

b. Provide student representatives from the S & A Fee Committee and the administration the opportunity to address the Board before decisions are made.

c. Take action on all or portions of the S & A fee budget not in dispute.

d. Take into consideration the results of the Dispute Resolution Committee and take final action on the budget.

4. Dispute Resolution Committee

Consists of three voting members appointed by the Board of Trustees, three voting S & A Fee Committee members who are students, one nonvoting student from the S & A Fee Committee who will serve as chair, and two nonvoting advisory members appointed by the College president.

The timelines and assignments for these groups are:

1. S & A Fee Committee

a. January – Receive budget proposals.

b. February - April – Draft budget recommendations.

c. May – Finalize budget recommendations.

2. ASCC Finance Director

a. January – Consolidate budget proposals.

b. February – Perform staff role for Committee.

c. March – Prepare draft budget summary from S & A Fee Committee.

d. April – Prepare budget summary.

e. May  – Prepare budget detail document.

f. June – Distribute budget document.

3. The Administration

a. May – Receive draft proposed budget.

Submit written differences to S & A Fee Committee and Dispute Resolution Committee.

Write Board agenda item on budget and issues of dispute.

c. June – Write Board agenda item for final budget approval.

4. Board of Trustees

a. June – Adopt budget in detail; final action on disputes.

5. Dispute Resolution Committee

a. May – Resolve disputes, if any.

450.070 RESERVES AND FUND BALANCES

Clark College will maintain a total of ten percent of its General Operating Budget within its Discretionary Fund Balances as a “Reserve” to allow for fluctuations in revenue and/or expenditure amounts in any given fiscal year. Dedicated Fund Balances will not be included in the College “Reserve.” Five percent of this reserve is set aside for the costs of disaster recovery to restore College operations and five percent is set aside for unexpected downturns in revenue such as reductions in state allocations or less than expected tuition revenue. Only the Board of Trustees can authorize a reserve of less than 10% for any one fiscal year at a time. Unless additional action is taken by the Board, the reserve will return to 10% the following fiscal year.

In addition to maintaining ten percent of its General Operating Budget as reserves for disaster recovery and reductions in revenue, the College will maintain dedicated funds for the following:

  • Technology upgrades (Communications and Information Systems account)
  • Parking lot maintenance and repair
  • Certificate of Participation (COP) repayment in the event ASCC does not have funds to maintain the payment schedule
  • Litigation reserve to be used for settlements, legal fees, and other costs incurred as a consequence of litigation and claims not covered by the State Agency Self Insurance Liability Program.
  • Capital projects to be used for the costs of capital projects not covered by other funding sources
  • Program continuity reserve to fund costs of high priority programs that have been funded for a limited time by external sources, and
  • Other items or initiatives that have been identified as high priority in the College’s efforts to serve students, maintain accreditation and fulfill its mission and vision.

Reserves and fund balance levels will be reviewed each year with the Board of Trustees.  Reserve amounts in excess of the 10% amount for items listed above will be recommended for Board approval annually.

If future state-level budget cuts appear likely, it may be appropriate to bring the balances to a higher level, allowing the College to maintain valuable infrastructure during reduction periods.

Board of Trustees’ approval is required for the use of these funds. In case of an emergency the president has the authority to draw on these funds and provide the Board with a report for ratification at its next meeting.

The administration is authorized, provided there are discretionary fund balances, to use excess fund balances for expenditures that support the vision and mission of the College. Discretionary fund balances are not available to fund ongoing operational needs.

Definitions

The General Operating Budget is composed of the state allocation (Fund 101), tuition and operating fees (Fund 149), worker retraining (Fund 123), dedicated revenues (Fund 148), and running start (Fund 145).  This budget is considered to represent the basic ongoing operations of the College.

Dedicated Fund Balances are those portions of the fund balances that are committed or accounts with fund balances that are not discretionary due to their fund source or purpose.  Fund 145 – Grants and Contracts; Fund 147 – Local Capital; Fund 148 – Lab Fees, Continuing Education, and Resale; Fund 149 – Tuition and Fees; Fund 522 – ASCC; Fund 790 – Payroll; Fund 840 – Trust and Agency Funds;

Fund 846 – Financial Aid Grants; Fund 849 – Student Loans; Fund 850 – Work Study; and Fund 860 – Long Term Student Loans represent funds in this category.

Discretionary Fund Balances are those portions of the fund balances that have been generated by College operations and have not been committed to specific projects. The primary funds and activities in this category are Fund 145 – Running Start and Grant Overhead; Fund 147 – Local Capital (not yet obligated); Fund 148 – Excess Enrollment; Fund 440 – Central Stores; Fund 443 – Data Processing; Fund 448 – Printing/Copy Machines; Fund 460 – Motor Pool; Fund 524 – Bookstore; Fund 528 – Parking; and Fund 570 – Auxiliary Services (Events, Food Service, Vending Machines, and Director of Auxiliary Services.)

Revised Policy/Procedure Approved by Executive Cabinet
November 30, 2010

450.075 IDENTITY THEFT PREVENTION PROGRAM

Program Adoption

ClarkCollege developed this Identity Theft Prevention Program ("Program") pursuant to the Federal Trade Commission's (“FTC”) Red Flags Rule, which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. This Program was developed with oversight and approval of the Clark College Board of Trustees. After consideration of the size and complexity of the College’s operations and account systems, and the nature and scope of the College’s activities, the Clark College Board of Trustees determined that this Program was appropriate for the College, and therefore approved this Program on April 27, 2009.

Definitions and Program

1. Red Flags Rule Definitions Used In This Program

“Identity Theft” is a “fraud committed or attempted using the identifying information of another person without authority.”

A “Red Flag” is a “pattern, practice, or specific activity that indicates the possible existence of Identity Theft.”

A “Covered Account” includes all student accounts or loans that are administered by the College including, but not limited to:

a. Student Tuition Easy Payment Plan
b. Emergency Loan
c. Student Refunds 
d. Student Financial Aid
e. Payment Agreements For The Repayment Of Financial Aid Funds

“Program Administrator” is the individual designated with primary responsibility for oversight of the program. See “Program Administration” below.

“Identifying information” is “any name or number that may be used, alone or in conjunction with any other information, to identify a specific person,” including name, address, telephone number, social security number, date of birth, government issued driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number, student identification number, computer’s Internet Protocol address or routing code.

2. Fulfilling Requirements Of The Red Flags Rule

Under the Red Flags Rule, the College is required to establish an “Identity Theft Prevention Program” tailored to its size, complexity, and the nature of its operation.  Each program must contain reasonable policies and procedures to:

a. Identify relevant Red Flags for new and existing covered accounts and incorporate those Red Flags into the Program.

b. Detect Red Flags that have been incorporated into the Program.

c. Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity Theft.

d. Ensure the Program is updated periodically to reflect changes in risks to students or to the safety and soundness of the student from Identity Theft.

Identification of Red Flags

In order to identify relevant Red Flags, the College considers the types of accounts that it offers and maintains, methods it provides to open its accounts, methods it provides to access its accounts, and its previous experiences with Identity Theft. The College identifies the following Red Flags in each of the listed categories:

1. Suspicious Documents – Red Flags

a. Identification document or card that appears to be forged, altered, or inauthentic.

b. Identification document or card on which a person’s photograph or physical description is not consistent with the person presenting the document.

c. Other document with information that is not consistent with existing student information.

d. Application for service that appears to have been altered or forged.

2. Suspicious Personal Identifying Information – Red Flags

a. Identifying information presented that is inconsistent with other information the student provides (example: inconsistent birth dates).

b. Identifying information presented that is inconsistent with other sources of information (for instance, an address not matching an address in student records).

c. Identifying information presented that is the same as information shown on other applications that were found to be fraudulent.

d. Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address).

e. Social security number presented that is the same as one given by another student.

f. A person fails to provide complete personal identifying information on an application when reminded to do so.

g. A person’s identifying information is not consistent with the information that is on file for the student.

3. Suspicious Covered Account Activity or Unusual Use of Account – Red Flags

                         a.     Change of address for an account followed by a request to change the student’s name.
                         b.     Payments stop on an otherwise consistently up-to-date account.
                         c.     Account used in a way that is not consistent with prior use.
                         d.     Mail sent to the student is repeatedly returned as undeliverable.
                         e.     Notice to the College that a student is not receiving mail sent by the College.
                         f.      Notice to the College that an account has unauthorized activity.
                         g.     Breach in the College’s computer system security.
                         h.     Unauthorized access to or use of student account information.

 

4. Alerts from Others – Red Flag

Notice to the College from a student, Identity Theft victim, law enforcement or other person that the College has opened or is maintaining a fraudulent account for a person engaged in Identity Theft.

Detecting Red Flags

1. Student Enrollment – in order to detect any of the Red Flags identified above associated with the enrollment of a student, College personnel will take the following steps to obtain and verify the identity of the person opening the account:

Detect

a. Require certain identifying information such as name, date of birth, academic records, home address or other identification.

b. Verify the student’s identity at time of issuance of student identification card (review of driver’s license or other government-issued photo identification or original passport or visa for international students), to the extent allowed by law.

2. Existing Accounts – in order to detect any of the Red Flags identified above for an existing Covered Account, College personnel will take the following steps to monitor transactions on an account:

Detect

a. Verify the identification of students if they request information (in person, via telephone, via facsimile, via e-mail).

b. Verify the validity of requests to change billing addresses by mail or e-mail and provide the student a reasonable means of promptly reporting incorrect billing address changes.

c. Verify changes in banking information given for billing and payment purposes.

Preventing and Mitigating Identify Theft

In the event College personnel detect any identified Red Flags, such personnel shall take one or more of the following steps, depending on the degree of risk posed by the Red Flag:

1.     Prevent And Mitigate

        a. Continue to monitor a Covered Account for evidence of Identity Theft.

                          b. Contact the student or applicant.
                          c. Change any passwords or other security devices that permit access to Covered Accounts.
                          d. Not open a new Covered Account.
                          e. Provide the student with a new student identification number.
                           f. Notify the Program Administrator for determination of the appropriate step(s) to take.
                          g. Notify law enforcement.
                          h. File or assist in filing a Suspicious Activities Report (“SAR”).
                           i.Determine that no response is warranted under the particular circumstances.

2. Protect Student Identifying Information.

In order to further prevent the likelihood of Identity Theft occurring with respect to Covered Accounts, the College will take the following steps with respect to its internal operating procedures to protect student identifying information.

a. Ensure that its website is secure or provide clear notice that the website is not secure.

b. Ensure complete and secure destruction of paper documents and computer files containing student account information when a decision has been made to no longer maintain such information.

c. Ensure that office computers with access to Covered Account information are password protected.

d. Avoid use of social security numbers.

e. Only release student information to the student in compliance of FERPA laws, unless a consent form has been completed by the student.

f. Ensure computer virus protection is up-to-date.

g. Require and keep only the kinds of student information that are necessary for College purposes.

Program Administration 

1. Oversight

Responsibility for developing, implementing and updating this Program lies with the vice president of administrative services. The Program Administrator will be responsible for ensuring appropriate training of College staff on the Program, reviewing any staff reports regarding the detection of Red Flags and the steps for preventing and mitigating Identity Theft, determining which steps of prevention and mitigation should be taken in particular circumstances, and considering periodic changes to the Program.

2. Staff Training and Reports

College staff responsible for implementing the Program shall be trained either by or under the direction of the Program Administrator in the detection of Red Flags and the responsive steps to be taken when a Red Flag is detected.

3. Program Updates

The Administrator will periodically review and update this Program to reflect changes in risks to students and the soundness of the College from Identity Theft. In doing so, the Administrator will consider the College’s experiences with Identity Theft situations, changes in Identity Theft methods, changes in Identity Theft detection and prevention methods, and changes in the College’s business arrangements with other entities.  After considering these factors, the Program Administrator will determine whether changes to the Program, including the listing of Red Flags are warranted. If warranted, the Administrator will update the Program.

New Policy/Procedure Approved by the Board of Trustees
  April 27, 2009