Preventing and Mitigating Identity Theft. We have reviewed our covered accounts, how we open and allow access to them, and our previous experience with identity theft, as well as new methods of identity theft we have seen or foresee as likely. Based on this and our review of the FTC’s identity theft rules and its suggested responses to mitigate identity theft, as well as other sources, we have developed our procedures below to respond to detected identity theft Red Flags.
Preventing and Mitigating Identity Theft. Once a Red Flag has been detected by a Badcock employee or store personnel or a customer, law enforcement, or any other person notifies Badcock of possible identity theft in connection with a covered account or an existing covered account, CSARM or the Legal Department must be notified. The Senior Vice President of Credit Services and Account Receivables Management (CSARM) or his/her designee will determine Badcock’s response(s) to any Red Flags detected or identified. Such response(s) will be commensurate with the degree of risk posed and consideration of all the facts and circumstances. Appropriate responses may include, but are not limited to, the following ● Denying an applicant’s request to open an account; ● Denying access or use of an existing account; ● Monitoring a covered account for evidence of identity theft; ● Contacting the customer; ● Changing any passwords, security codes, or other security devices that permit access to the covered account; ● Reopening a covered account with a new account number; ● Notifying any credit reporting agencies to which Badcock has furnished information in connection with a covered account or any consumer associated with a consumer account; ● Closing an existing covered account; ● Not attempting to collect on a covered account; ● Notifying law enforcement; or ● Determining that no response is warranted under the particular circumstances.
