Number: STU 060
Effective: November 1, 2016
Department: Student Affairs
Last Revision: February 9, 2017


To provide for the implementation of an identity theft prevention program to detect, prevent and mitigate student identity theft.


Applies to all CWI employees, students, contractors and other persons or entities who have access to personal identifying information and/or covered accounts.


Covered account: All student accounts administered by CWI.

Identity theft: Fraud committed or attempted using identifying information of another person without authority.

Personal identifying information: Any name or number that may be used alone or in conjunction with other information to identify a specific person, including an individual’s name, address, date of birth, Social Security number, driver’s license number, passport number, tax identification number, student identification number or banking account information.

Red flag: a pattern, practice or specific activity that indicates the possible existence of identity theft.


As a creditor of its students, CWI is required to provide for the identification and detection of and response to red flags which could indicate student identity theft. Accordingly, the President shall develop an Identity Theft Prevention Program (ITPP) to control reasonably foreseeable risks to students from identify theft. Such a program will assist CWI in (1) identifying relevant red flags for new and existing covered accounts; (2) detecting new red flags; and (3) responding appropriately to any red flags that are detected.


CWI’s ITPP shall include procedures to address the following:

  1. Identification of Red Flags
  2. Detecting Red Flags
  3. Preventing and Mitigating Identity Theft 
  4. Program Administration