(A) The ultimate oversight of the program is the County Commissioners. The County Commissioners have assigned specific responsibility for the Program’s implementation to the Program Administrator.
(B) The Program Administrator will report to the County Commissioners, at least annually, on compliance by the County with all identity theft issues.
(C) The report will address material matters related to the Program and evaluate issues such as:
The effectiveness of the policies and procedures of the County in addressing the risk of identity theft in connection with the opening of covered accounts and with respect to existing covered accounts;
Service provider arrangements;
Significant incidents involving identity theft and management’s response; and
Recommendations for material changes to the Program.
The County Commissioners will take any additional steps necessary to support this program.