Palmer College of Chiropractic safeguards the confidentiality, availability and integrity of applicable identifying information through the implementation of rules and associated processes designed to detect, prevent and mitigate identity theft. Such rules and processes include, but are not limited to:

  1. Identify relevant red flags for covered accounts the college offers or maintains and incorporate those red flags into the program;
  2. Detect red flags that have been incorporated into the Program;
  3. Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
  4. Ensure the Program is updated periodically to reflect changes in risks to students and to the safety and soundness of the creditor from identity theft.

Scope

This policy applies to the entire College community and 3rd parties.

Definitions

  1. The term “covered account” means:
    1. An account that a creditor offers or maintains, primarily for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions. Covered accounts include utility accounts; and
    2. Any other account that the creditor offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the creditor from identity theft, including financial, operational, compliance, reputation or litigation risks.
  2. The term “credit” means the right granted by a creditor to a debtor to defer payment of debt or to incur debts and defer its payment or to purchase property or services and defer payment therefore.
  3. The term “creditor” means any person who regularly extends, renews, or continues credit; any person who regularly arranges for the extension, renewal, or continuation of credit; or any assignee of an original creditor who participates in the decision to extend, renew, or continue credit.
  4. The term “debtor” means any person who owes a creditor; or any person who has the obligation of paying a debt.
  5. The term “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, unique electronic identification number, computer’s Internet Protocol (IP) address, or routing code.
  6. The term “identity theft” means fraud committed or attempted using the identifying information of another person without authority.
  7. The term “red flag” means a pattern, practice or specific activity that indicates the possible existence of identity theft.

Administrative Rules

Identity Theft Prevention Program
  1. Personnel managing student or patient financial records should look for:
    1. Inconsistencies in the information the consumer gives you; date of birth differs from SSA issuance tables.
    2. An address, phone number, or other personal information that has been used on an account you know to be fraudulent.
    3. A false address, an address for a mail drop or a invalid phone number.
    4. A Social Security number used by someone else.
    5. An address or telephone number that has is used by many other people with active or past accounts.
    6. A person who omits required information on an application and does not respond to notices that the application/transaction is incomplete.
  2. Signs of suspicious account activity:
    1. Soon after you’re notified of a change of address, you’re asked to add users to the account.
    2. Mail that is sent to the consumer is returned repeatedly as undeliverable although transactions continue to be conducted on the account.
    3. You receive information that the customer is not receiving their account statements in the mail.
    4. You receive information about unauthorized charges to the account.
  3. Detecting red flags:
    1. New accounts: Verify the identity of the person who is opening a new account. Reasonable procedures may include getting a name, address, and identification number and, for in-person verification, checking a current government issued identification card, such as a driver’s license or passport.
    2. Existing accounts; Include reasonable procedures to authenticate customers (confirming that the person you’re dealing with really is your customer), monitor transactions and verify the validity of change-of-address requests.
  4. Preventing or mitigating identity theft
    1. Monitor a covered account for evidence of theft.
    2. Determine if a response is warranted under the particular circumstance and the extent of that response.
      1. Consider contacting a consumer if you suspect illegal activity.
      2. If there has been suspicious activity, consider closing the account and opening a new one.
      3. Consider notifying law enforcement
Oversight of the Program

Responsibility for developing, implementing and updating this Program lies with the Vice Chancellor for Administration and the Senior Director of Financial Affairs. The Senior Director of Financial Affairs will be responsible for the Program administration, for ensuring appropriate training of College employees on the Program, for reviewing any employee 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.

Updating the Program

This Program will be periodically reviewed and updated to reflect changes in risks to students and patients and the soundness of the College from identity theft. Annually, the Senior Director of Financial Affairs will consider the College’s experiences with identity theft, changes in identity theft methods, changes in identity theft detection and prevention methods, changes in types of accounts the College maintains and changes in the College's business arrangements with other entities. After considering these factors, the Senior Director of Financial Affairs will determine whether changes to the Program, including the listing of red flags, are warranted. If warranted, the Director of Senior Director of Financial Affairs will update the Program.

Employee Training

College employees who are responsible for implementing the Program shall be trained either by or under the direction of the Senior Director of Financial Affairs in the detection of red flags, and the responsive steps to be taken when a red flag is detected.

Oversight of Service Provider Arrangements

The College shall take steps to ensure that the activity of a service provider is conducted in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft whenever the College engages a service provider to perform an activity in connection with one or more covered accounts.

Contacts

Senior Director of Financial Affairs
Alexis VanderHorn
1000 Brady Street
Davenport, IA 52803
(563) 884-5102
alexis.vanderhorn@palmer.edu

Essential Elements Applicable to all Institutional Policies

Responsibilities

It is the responsibility of all employees and students to know and comply with this policy and all applicable laws and public ordinances. Further, employees and students are expected to review the proscribed conduct set forth in this policy, as well as, any associated division or department-specific procedures that describe policy implementation practices to ensure a clear understanding of the College’s expectations.

Disciplinary Action

Violent behavior is considered serious misconduct. Employees or students found to have conducted themselves in a manner prohibited by this policy may be subject to disciplinary action up to and including termination of employment and/or dismissal as a student.

Reporting Noncompliance

Filing a Report

Employees And Students

Employees, students or any other member of the College community should report allegations of noncompliance with this policy to the Office of Institutional Compliance and Quality Assurance through one of the designated individuals named below.

College Officials

Supervisors, administrators or any other College officials who witness; are directly advised of; or become aware of allegations of noncompliance with this policy are to immediately advise one of the designated individuals named below.

Palmer College of Chiropractic
Earlye Adams Julien, PHR, M.S. Ed., CQIA
Senior Director for Institutional Compliance & Organizational Development
1000 Brady Street
Davenport, IA 52803-5214
phone: (563) 884-5476
earlye.julien@palmer.edu

Palmer College of Chiropractic
Lori Larsen, B.A., Lead Coordinator
Also Serving as Compliance Coordinator
Office of Adjudication
1000 Brady Street
Davenport, IA 52803-5214
(563) 884-5246 or (800) 722-2586
lori.larsen@palmer.edu

Palmer College of Chiropractic
William DuMonthier, D.C., Dean of Student Academic Affairs
Also Serving as Compliance Coordinator
Office of Student Academic Affairs
90 E. Tasman Drive
San Jose, CA 95134-1617
(408) 944-6062
william.dumonthier@palmer.edu

Palmer College of Chiropractic
Cheryl Shaw, B.S., Human Resources Manager
Also Serving as Compliance Coordinator
4777 City Center Parkway
Port Orange, FL 32129-4153
(386) 763-2665
cheryl.shaw@palmer.edu

Confidentiality

The College shall maintain the confidentiality of the information they receive, except where disclosure is required by law, policy or is necessary to facilitate legitimate College processes, including the investigation and resolution of allegations.

The identity of participants in an investigation shall be maintained in confidence subject to the same limitations above.

Individuals who have reported questionable behavior or who have initiated or participated in the complaint procedures available are advised their identity may be known for reasons beyond the control of college officials or investigators.

Anonymity

Because of the inherent difficulty in investigating and resolving allegations from unidentified persons, the College discourages individuals from making anonymous reports of improper conduct. However, should the College receive an anonymous report, such report will be reviewed to determine the appropriateness and/or feasibility of a response.

Retaliation

The College strictly prohibits retaliation or reprisal of any kind against an individual who has reported questionable behavior or who has initiated or participated in the complaint procedures available. Allegations of retaliation shall constitute separate grounds upon which a complaint may be raised under this policy.

Reporting False Claims

Any individual who makes a claim under this policy in bad faith, or knows or has reason to know that such claim is false or materially inaccurate, shall be subject to disciplinary action up to and including termination.

Investigations

The College may determine an allegation of noncompliance with this policy requires an investigation. No one other than the appointed investigator will be allowed to conduct an investigation on behalf of the College. The College may impose any appropriate measures on an interim basis where there is a reasonable cause to believe that such action is needed for the health, safety or welfare of members of the College community or to avoid disruption to the work/educational environment including student suspension or employee administrative leave pending the outcome of an investigation.

Violation of Law and College Policies

Noncompliance with the College’s policies includes any behaviors covered under applicable laws. Individuals engaging in illegal activities may subject themselves to criminal penalties under the law.

Disciplinary proceedings may be instituted against an individual that potentially violates both the criminal law and the College’s policies (that is, if both possible violations result from the same factual situation) without regard to the pendency of civil or criminal litigation. Proceedings under this policy may be carried out prior to, simultaneously with, or following a civil or criminal proceeding at the discretion of the Chief of Compliance or designee. Determinations made or disciplinary actions imposed under this policy shall not be subject to change because criminal charges arising out of the same facts giving rise to violation of the College’s policies were dismissed, reduced or resolved in favor of or against the criminal law defendant.

When a student or employee is charged by federal, state or local authorities with a violation of law, the College will not request or agree to special consideration for that individual because of his or her status as a student or employee with the College. If the alleged offense is also being processed under College policy, the College may advise legal authorities of the existence of the College’s policies and how such matters are typically handled within the College community.

Contact Us

Davenport, Iowa, Campus
Student Services
(563) 884-5857

San Jose, Calif., Campus
Student Services
(408) 944-6020

Port Orange, Fla., Campus
Student Services
(386) 763-2724

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