Case study: personal diary

• A Road Story
  The Coueignoux household lives in Massachusetts and rarely take trips out of state.
  In July '04, Mrs Coueignoux helped her daughter Stéphanie drive to Nebraska, her first posting as a fledging TV anchor reporter.
  Shortly thereafter a credit card representative contacted the Coueignoux by phone, concerning the validity of a string of transactions made in several places along route 80, from Ohio to Iowa to Nebraska.
  
• A Taxing Case
  In April '05, the Coueignoux household filed their Federal Income Tax Return for 2004 electronically for the first time.
  The filing was rejected twice, forcing the Coueignoux to mail a paper return as in past years.
  IRS justified the rejections on the ground that the SS number provided for Mr Coueignoux did not match the Social Security records.
  Indeed, after enquiries, Mr Coueignoux was told the SS number he has used for the past 30 years was in the name of Mr Coveignoux.

Topic notes

Relevant legal, regulatory documents and industry standards:

• the Fair Credit Reporting Act (FCRA - 15 USC section 1681 et seq), as amended in Oct 2001
• the Fair and Accurate Credit Transactions Act (Dec 2003) (Public Law 108-159)
• the Fair Credit Reporting Act (FCRA), as amended by FACTA, (all undated provisions were put in force during 2004)
  setting the responsabilities of the credit reporting agencies, their suppliers of information and their customers
• bill sponsored by Senator Mark Pryor on consumer ability to freeze credit reports (for context)
• the Gramm-Leach-Bliley Act (GLBA Public Law 106-102) Nov 1999
  the relevant text, title V, will be revisited in chapter II-2 Marketing Campaigns and chapter III-1 Protecting Digital Information
• Payment Card Industry (PCI) Data Security Standard, as downloaded from Visa site (Dec 2004)
  setting the responsabilities of merchants and services providers

more information from:

• the Federal Trade Commission:
  • rules, reports and useful links related to FCRA and FACTA
  • consumer advice: how to get a free credit report
• the Privacy Rights Clearinghouse
• pro-consumer organizations Consumers Union and the National Consumer Law Center

PCI standard enforcement:

• the basics
• Visa's enforcement program
• Security scanning (using a third party compliant vendor)
• Self assessment
• Annual audit
  These documents, revisable without notice, have been downloaded from Visa(July 2005). Mastercard has similar policies in place.