A recent survey showed that 70% of the UK population own a smart phone and nearly 30% own a tablet. Many employees and volunteers have personal devices that are more modern and functional than those that are provided for them at their workplace and an increasing number of people want to use their personal devices at work.
Known as ‘bring your own device’ (BYOD) this trend has many benefits including increased efficiency, flexibility and employee morale. But it also carries a number of risks organisations must consider when allowing employees’ devices to be used to process work-related personal information.
in 2013 The Royal Veterinary College received a warning from the Information Commissioner’s Office (ICO) after a member of staff lost a camera, which included a memory card containing the passport images of six applicants. The organisation had no guidance in place explaining how personal information stored for work should be looked after on personal devices.
Simon Rice, ICO Technology Manager said:
“As the line between our personal and working lives becomes increasingly blurred it is critical employers have a clear policy about personal devices being used at work.
“The benefits must be balanced against the potential risks to work-related personal data but the organisation should not underestimate the level of effort which may be required to ensure that the processing of personal data with BYOD remains compliant with the Data Protection Act (DPA). Remember, it is the employer who is held liable for any breaches under the DPA.”
The ICO’s key ‘bring your own device’ recommendations are:
Ensure devices are secure
It is important to ensure that personal data is protected against unauthorised or unlawful access. There are a range of simple ways to achieve this but all need to be in place before an incident occurs.
• Ensure devices are locked with a strong password;
• Use encryption to store data on the device securely;
• Maintain a clear separation between the employee’s private and work data, for example, by only using apps which you have approved for business use and use separate apps for personal use.
Ensure data transfers are secure
Transferring data between personal devices and organisation’s systems presents its own set of risks, which need to be anticipated and minimised.
• Transfers of personal data should be done via a secure channel;
• Be careful of untrusted connections, for example open Wi-Fi networks in coffee shops;
• Only use public cloud-based sharing and public backup services which you have not fully assessed with extreme caution, if at all.
If the device is lost or stolen ensure you can prevent any work-related personal data from being accessed.
• Register devices with a remote locate and wipe facility in the event of a loss or theft;
• Make sure users know exactly which data might be automatically or remotely deleted and under which circumstances.
Have an ‘end of contract’ policy
When an employee or volunteer leaves the organisation or replaces their device, have a policy in place to secure work-related accounts and information.
• Change the password and revoke all access to facilities such as the company email, intranet and social media
• Provide information on how users should delete the data on the device prior to disposal, resale or recycling.
Have a clear Acceptable Use Policy
It’s important that everyone understands their responsibilities.
• Implement and maintain an Acceptable Use Policy to provide guidance and accountability of behaviour;
• Consider if this needs to link to your Social Media Policy if BYOD leads to an increased use of social media;
• Be clear about which types of personal data may be processed on personal devices and which may not;
Further guidance on BYOD is available at http://ico.org.uk/for_organisations/data_protection/topic_guides/online/~/media/documents/library/Data_Protection/Practical_application/ico_bring_your_own_device_byod_guidance.ashx