Potential Fraudulent Student Records

Procedure Statement

Potential fraudulent applicants may be identified by Durham Tech staff or the North Carolina Community College System Office (NCCCS) Regional Security Officer. The Regional Security Officer will notify the Vice President/Chief Operating Officer if a fraudulent student account is identified at another institution for a student with an account at Durham Tech.  Indicators may include, but are not limited to, multiple applications received within a short period from out-of-state addresses, high schools that cannot be verified through the Department of Education, or Residency Certification Numbers (RCNs) assigned to another student. The NCCCS Office has provided the following recommendations for confirmed fraudulent accounts in addition to local screening processes:

1. Review student record and determine if and what activity has (or hasn't) taken place (e.g., mass emailing about student job opportunities, a lack of actual registration/student activity, etc.).
2. Pursue any steps to validate your instance of the account.
3. Disable any confirmed or suspected accounts.
4. Identify and investigate any other accounts that may have sent out the same or similar content to determine if they are fraudulent or compromised.
5. Purge any confirmed malicious emails that were sent from offending accounts from any inboxes within your organization.
6. Investigate any instances where a user has clicked on the malicious URL embedded in the phishing email.
7. Review/consider blocking the URL contained within any malicious emails.
8. Review/consider enhancing the limits set for users to send email/mass emailing (especially for students) based on known or determined baselines and business needs.
9. If financial aid has been awarded or is pending for these students, it is recommended that disbursement be delayed until identity verification is complete.
10. If you are unable to locate the student at your college based on the information provided, please reach out to your Information Security Officer (ISO) to retrieve the college's specific email address assigned. Any correspondence with the ISO should be carbon copied to the Vice President/Chief Operating Officers or submit a ticket in Service Now.

Procedure

Campus Identification and Notification of Potential Fraudulent Applicant

To mitigate identity theft and network security violations, Durham Tech has established the following procedure to identify potential fraudulent applicants and prevent registration during the investigation process.

1. The first point of contact for the staff member will be the immediate department supervisor or designee.
2. The department supervisor or designee will submit an Information Technology Services (ITS) work order using the category Fraudulent Application. A comment must be added to include the student Colleague Identification Number (CID), a justification of the concern, and attached documents or screenshots of any available evidence. The following staff must be added to the CC list of the work order:
   1. Vice President, Chief Operating Officer  
   2. Executive Director/Chief Technology Officer
   3. Assistant Vice President, Student Services
   4. Registrar
   5. Director, Advising
   6. Director, Financial Aid and Veteran Affairs
   7. Director, Enrollment Management and CRM Strategy
   8. Business Applications Analyst
   9. Director, Scheduling and Compliance
3. Once the work order is submitted, the following staff will complete designated tasks.
   1. Registrar
      1. Add Potential Bogus Record (PBR) alternate ID type to DADD form in Colleague. This will prevent registration until student identity is confirmed.
      2. Contact the student to verify identity before proceeding with enrollment steps.
      3. Add comment to ITS work order indicating PBR type has been added.
   2. Director, Enrollment Management and CRM Strategies
      1. Collaborate with the Registrar to review fraud risk indicators identified in the CRM.
      2. Review existing outgoing and incoming communications.  
      3. Add comment documenting the assessed risk level (low, medium, or high).
   3. Director, Financial Aid and Veteran Affairs
      1. Review grant and loan activity and verify eligibility status.
      2. Flag student for verification.
      3. Add comment to the work order documenting status.
   4. Director, Advising
      1. Continue advising the student during the initial investigation.
4. If the applicant’s identity is confirmed, the Registrar will change the alternate ID type to PB Record Resolved (PRR) on the DADD form in Colleague. This will release the registration hold for the student and alert the North Carolina Community College System office that the record has been resolved.
5. If the applicant’s identity cannot be confirmed and the application is determined to be fraudulent, the following staff will complete designated tasks.
   1. Registrar
      1. If student is registered for any courses, the student will be deregistered.
      2. Update the Privacy Status on the BIO form in Colleague to X (follow the process outlined in section 6 of Duplicate Record Cleanup Process).
      3. Enrollment for fraudulent student records should not be reported to the National Student Clearinghouse (NSC). If the fraudulent student was reported, the college should determine whether the student must be removed from the NSC system. If the record does not require removal, the next enrollment report should indicate the student's status as Withdrawn, with a Status Start Date equal to the day before the Term Begin Date.
   2. Director, Enrollment Management and CRM Strategies
      1. Deactivate the Element451 account and retain all relevant logs.
      2. Add comment to the work order documenting status.
   3. Director, Financial Aid and Veteran Affairs
      1. Follow the process provided by the Department of Education for reporting.
      2. Add comment to the work order documenting status.
      3. If the college determines the records should be removed from NSC system, a letter from the Office of Inspector General (OIG) must be provided to the NSC legal team. For more information, colleges can contact the NSC at schoolops@nationalstudentclearinghouse.org.
   4. Business Application Analyst
      1. Disable the Colleague account and retain all relevant logs.
      2. Notify ITS staff to review communications, disable the college email account, and retain all relevant logs.
   5. Director, Scheduling and Compliance
      1. FTE generated by fraudulent student records should not be included in the 
         Institutional Class Report (ICR) for the applicable term. 

Definitions

Potential Fraudulent Application - A formal request for a college account that deliberately contains false, manipulated, or stolen information to deceive the College. The malicious intent is typically to obtain financial aid disbursements primarily executed for financial gain, personal advantage, or to bypass eligibility requirements. It serves as a foundational step for broader financial crimes like identity theft, to include financial aid identity theft.