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RED FLAG REGULATIONS
FTC Section 609(e)
NOW REQUIRED BY FEDERAL REGULATION FOR ALL VETERINARY HOSPITALS

Identity theft and ensuring the identity of our clients
  1. The Federal Trade Commission (FTC), the nation’s consumer protection agency, enforces the Fair Credit Reporting Act (FCRA). Section 609(e) of the FCRA requires all businesses that provide credit, goods or services to any individual to ensure the identity of that person.
  2. Section 609(e) is designed to limit identity theft. All business that provide clients with any form of credit, or offer services that a client can pay for with a credit card, money order, check, debit card, or cash are now required to conform to this regulation.
  3. This means that we are required to check the identification of each individual that provides payment in the form of check, money order, debit card or credit card.
  4. We are required to check the identification of each individual that picks up patients (no matter what form of payment is provided). Should a client arrange to have their pet picked up by another individual we need to know the name of that individual and that person should be expected to show a valid ID before the pet is released. The client is required by the FCRA to provide a WRITTEN authorization allowing this other individual to pick up their pet.
  5.   A valid ID is defined as a picture ID in the form of a valid Military ID card, valid Driver’s License or other valid State recognized/provided picture ID (such as an individual picture ID provided by the DMV). Student ID’s and Social Security Cards are not acceptable. 
  6. Visual inspection of the ID, the individual, and the individual’s signature is all that is required by Section 609(e) of the FCRA. No written information is required to be kept in the client’s file. 
  7. We are not authorized to release personal information on any client or patient over the phone.
  8. We are not authorized to release any personal information on a client or patient information over the phone or by fax without the WRITTEN approval of the client.
  9. We do not maintain credit card numbers, checking account numbers, social security number, or any other personal financial information on any client unless specifically authorized in WRITING by the client. Should the client require us to maintain this information in their file we ARE NOT authorized to discuss it with anyone that is not the client.
  10. After 3 years, all medical records for any patient will be shredded should the patient’s file become inactivated.
  11. All financial records (if any) for any client shall be returned or provided to the client upon request or any authorized law enforcement officer acting on the behalf of an identify thief victim. 
  12. All requests for documents MUST be submitted in WRITING per Section 609(e) of the FCRA.
  13. All individuals claiming identify theft must provide proof of identity, like a government-issued ID card, the same type of information the identity thief used to open the account or medical file, or the type of information we are currently requesting from clients; with a police report and completed affidavit. 
  14. Any and all records required by a client that will show proof of identify theft must be provided upon request. 
  15. If we CANNOT verify the true identity of the person asking for information we can refuse to provide any information or documentation. We can refuse to release a patient to anyone that we cannot verify their true identity or verify their right to pick up the patient.
  16. If you have any questions, or if problems arise please contact Dr. Brooks for clarification.