WAKEFIELD PUBLIC SCHOOLS Policy of the School Committee

Policy: 102-R-E

FEDERAL RED FLAG RULE POLICY The School Administration will develop a comprehensive Federal Red Flag written process for the Wakefield Public Schools which maintains conformance with the Federal Red Flag rule. The scope of the process shall be reviewed and updated annually and any changes will be presented to the Wakefield School Committee. A copy of the referenced procedural process can be viewed in the Office of the Superintendent. The Red Flags Rule is part of the Fair and Accurate Credit Transaction (FACT) Act of 2003. The overall intent of the Rule is to mitigate instances of identity theft. The Rule requires creditors to develop and implement programs that provide for the identification, detection and response to “red flags” that could indicate identity theft. Under the federal rules, it was determined that this applies to school districts because credit is extended by a school district every time a parent, etc. pays a school district after the service to which the money is owed was provided. Simultaneously, while not required to do so, this policy also complies with the Massachusetts Data Security laws contained in 201 CMR 17.00. Identity Theft Prevention written procedures The Wakefield School Department's designated Data Security Coordinator will be the Business Administrator or his/her designee. Annual training sessions for district employees who have access to personal information contained in the records or files of the District. “Personal Information” is specifically defined in the process. Review of the scope of the security measures of the process at least once annually Regular testing of the plan's safeguards Appropriate response to any potential breaches of an employee's personal information. Require third party sign-off on vendors that may have access to employee's personal information. District employees who have access to personal information must sign the Red Flag Policy Acknowledgement Form when they are newly hired or when there is a change to the written process.

Adopted: May 10, 2011; Revised: April 2014 Legal Ref: Fair & Accurate Credit Transaction (FACT) Act of 2003; Mass Data Security laws in 201 CMR 17:00