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Identity Theft Prevention
- obtain or use consumer reports in connection with a credit transaction;
- furnish information to consumer reporting agencies in connection with a credit transaction; or
- advance funds to (or on behalf of) someone, except for funds for expenses incidental to a service provided by the creditor to that person.
Without a regulatory requirement for extensive documentation, simple practice policy and training resources can be used for this purpose. For instance, a small practice may create a table (1-page Word file; About Downloading) of practice policies that support activities for preventing identity theft. The practice can then indicate for each item the policy or action to be taken, or where a related written policy already exists.
You may also wish to develop or change some existing documents, such as amending a HIPAA Business Partner Agreement to require these entities to adopt policies to detect and protect against identity theft.