ICO encourages businesses to introduce bring your own device policies

“The growing use of smartphones and other personal devices in the work place can leave businesses vulnerable” says Morgan J Morgan, Dyne Drewett’s Head of Corporate Commercial, “the recent case of the Royal Veterinary College (RVS) demonstrates the risks involved”.

The RVS recently gave an undertaking to the ICO, following a data breach involving the theft of an employee’s personal camera memory card on which photographs of six job applicants’ passports were stored. The RVS had no guidance in place on the storage of personal information for work purposes on personal devices.

The Information Commissioner’s Office (ICO) has highlighted the increasing use of personal devices (smartphones, tablets and laptops) for work purposes. The ICO suggests that businesses should update data protection policies and provide staff with guidance and training in response to this trend.

The checklist below highlights the potential risks and benefits of allowing employees to use their own personal mobile devices for business purposes.

What is bring your own device (BYOD)?

Many employees now own personal mobile devices (such as tablets, smartphones, laptops or notebook computers) that can be used for business purposes. Businesses are receiving an increasing number of requests to allow employees to use these devices at work.

BYOD benefits

BYOD can bring a number of benefits to businesses, including:

• Increased flexibility and efficiency in working practices.
• Improved employee morale and job satisfaction.
• A reduction in business costs as employees invest in their own devices.

BYOD risks

The boom in BYOD has been matched with an upsurge in activity by criminals trying to exploit the data and intellectual property stored on personal mobile devices. The use of personal mobile devices for business purposes increases the risk of damage to a business’s:

• IT resources and communications systems.
• Confidential and proprietary information.
• Corporate reputation.

Ownership of the device

Personal mobile devices are owned, maintained and supported by the user, rather than the business. This means that a business will have significantly less control over the device than it would normally have over a traditional corporately owned and provided device.

Securing data stored on the device

A business is responsible for protecting company data stored on personal mobile devices. Businesses should consider implementing security measures to prevent unauthorised or unlawful access to the business’s systems or company data, for example:

• Requiring the use of a strong password to secure the device.
• Using encryption to store data on the device securely.
• Ensuring that access to the device is locked or data automatically deleted if an incorrect password is inputted too many times.

The business should ensure that its employees understand what type of data can be stored on a personal device and which type of data cannot.

Mobile Device Management

Mobile Device Management software allows a business to remotely manage and configure many aspects of personal mobile devices. Typical features include:

• Automatically locking the device after a period of inactivity.
• Executing a remote wipe of the device (make sure employees are aware which data might be automatically or remotely deleted and in which circumstances).
• Preventing the installation of unapproved apps.

Monitoring use of the device

If a business wants to monitor employees’ use of personal mobile devices, it must:

• make its  reasons for monitoring clear; and
• explain the benefits the business expects will be delivered by monitoring (for example, preventing misuse of the device).

The business must ensure that monitoring technology remains proportionate and not excessive, especially during periods of personal use (for example, evenings and weekends).

Loss or theft of the device

• The biggest cause of data loss is still the physical loss of a personal mobile device (for example, through theft or by being left on public transport).
• Loss or theft of the device could lead to unauthorised or unlawful access to the business’s systems or company data. The business must ensure a process is in place for quickly and effectively revoking access to a device in the event that it is reported lost or stolen.
• Businesses should consider registering devices with a remote locate and wipe facility to maintain confidentiality of the data in the event of a loss or theft.

Transferring data

• BYOD arrangements generally involve the transfer of data between the personal mobile device and the business’ systems. This process can present risks, especially where it involves a large volume of sensitive information. Transferring the data via an encrypted channel offers the maximum protection.
• Employees should be encouraged to avoid using public cloud-based sharing which have not been fully assessed. Businesses should consider providing guidance to employees on how to assess the security of wi-fi networks (such as those in hotels or cafes).

Departing employees

A business needs to think about how it will manage data held on an employee’s personal mobile device should the employee leave the business.