Despite standards that are beginning to emerge, such as the UK ICO’s recent guidance for BYOD policies, issues surrounding employees’ use of personal devices for corporate work remain a fairly sticky wicket. At the IAPP Europe Data Protection Intensive in London, a panel discussion and presentation, “BYOD: What’s All the Fuss,” sought to provide a bit of clarity through personal experiences at the likes of Vodafone, the BBC and global medical research firm Beckman Coulter.
Much of the advice delivered could be summed up thusly by Paula Barrett, a partner at Eversheds LLP and host of the discussion: “Don’t assume that executives just happen to know to do basic things.”
Sure, there is available technology—like those “sandbox” tools that put an envelope around corporate data, think Citrix, even on mobile devices—that can help with corporate BYOD policies, but much of an effective policy is going to depend on training employees to use their devices appropriately and actually instill in them a desire to follow the polices they’ve been trained on.
“Focus on actual practical guidance,” Barrrett said, “not legalistic stuff. What data should they be downloading, what apps, what are the dangers?”
And you’d better do it now. Your employees are already bringing corporate data onto their personal devices, whether you like it or not, so outlining a policy as soon as possible is vital to protect corporate interests. A recent Cisco study can let you know if you’re in line with other corporations in terms of what devices you supply and what you allow on things like personal phones, laptops and tablets, but what you allow and what’s actually happening are two different things.
Why? Well, said James Leaton Gray, head of information policy and compliance at the BBC, “Journalists, like magpies, are attracted to shiny things. A number of people could be seen wandering around after Christmas like Gollum, like ‘oooh, my precious,’ and executives are not excluded from this.” Has anyone else had the experience, Gray wondered, where an executive gets herself a shiny new tablet and, presto, the BYOD rules change to allow it?
“The reality is,” Gray reasoned, “that there’s been a massive price drop for technology, that meant that suddenly people were able to buy themselves something far more up to date than anything on the corporate catalog.”
For Kasey Chappelle, CIPP/US, global privacy counsel for Vodafone Group Services Limited, the problem was even more pronounced: “When you work for a telecom, you can’t very well tell them they can’t use the toys that we sell,” she said. “We are our own company’s best ambassadors. And people find workarounds anyway. Even if we didn’t allow a connect to the network, they would hack in; they’ll have neat jerry-rigged things.”
Of course, when Chappelle went to the IT team to try to put a BYOD policy in place, she heard, “We already have a policy. It doesn’t happen…Meanwhile, the privacy and litigation lawyers were finding ways to paper over the problem, with policies and procedures to protect ourselves from risks. But really, the solutions are primarily technological in nature.”
Chappelle highly recommended a mobile device management vendor. “No matter what program you use, if you’re not using a mobile device management system, you’re doing it wrong,” she said. “Those MDM systems forestall a lot of the privacy and security issues that could be raised.”
At Vodafone, they’ve developed a solution that will soon be available that allows for a dual persona on personal devices. “It allows you to switch over from business persona to personal persona and you have to log in to one or the other,” Chappelle sad. “And it has other neat features. It gives an employee a dashboard for managing information on the device, and has lots of self-help functions. I’ve played with it a bit and it makes it really simple and seamless.”
Don’t have something like that on board yet? No worries. A big firm like Beckman Coulter doesn’t either. “We’ve not got any technology like that,” said Hazel Polka, assistant general counsel, EMEAI, at Beckman, “because we have not officially implemented our policy in Europe. We don’t’ have much experience with what will happen, but we’ve got a lot of concern expressed by those who know this is waiting in the wings, both from corporate and employees.”
Don’t be surprised when you run into regional issues, Polka warned a crowd that nodded its collective head vigorously. “It was very much that IT wrote this policy and then figured they should probably run it past legal,” she said of her experience, “and then they ran it past the folks in the U.S., and then they forwarded it to me, and I took one look and said, ‘I think it might be more complicated than that, actually.’ That was six months ago, and let’s just say the policy hasn’t been yet implemented in Europe.”
Communication with local works councils is vital, she said, and, “I’ve needed to seek out the engagement of HR and others to cover some of the gaps.”
Perhaps that’s the other overarching theme each of the panelists agreed with, alongside vigorous and easy-to-understand training: Rally your stakeholders. The privacy team is likely uniquely positioned in the company to outline the complexities of BYOD—just try sorting through the tax implications of issuing a stipend for personal devices on a global basis—and evaluate the risks. Getting disparate entities like IT, HR and investor relations all on board form the start is vital to crafting an effective BYOD policy.
Well, that and being able to effectively explain why the company has the right to completely wipe the contents of someone’s personal phone should it be lost…