Consumer Device Policy (Smartphones / Tablets) BYOD (Bring Your Own Device)
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1 Consumer Device Policy (Smartphones / Tablets) BYOD (Bring Your Own Device) Policy Number: 422 Supersedes: - Standards For Healthcare Services No/s 1, 5, 19 New Version Date Of Reviewer Completed Date Approved by: Review No: Review: Name: Action: Approved: Date: 0.2 January 2014 Completed 3 years Brief Summary of Document: The policy relates to any staff member (or manages a staff member) who uses the Choose Your Own Device (CYOD) or Bring Your Own Device (BYOD) scheme in Hywel Dda University Health Board. To be read in conjunction with: Information Security Policy Mobile Working Policy Policy Internet Access and Usage Policy Classification: Corporate Category: Policy Freedom Of Information Status Open Authorised by: Paul Hawkins Job Title Chief Operating Officer Signature:
2 Responsible Officer/Author: Contact Details: Sarah Odishow Job Title: Informatics Business Manager Dept Informatics Base Glangwili General Hospital Tel No Scope ORGANISATION WIDE DIRECTORATE DEPARTMENT ONLY COUNTY ONLY Staff Group Administrative/ Estates Medical & Dental Nursing Allied Health Professionals Ancillary Maintenance Scientific & Professional Other CONSULTATION Please indicate the name of the individual(s)/group(s) or committee(s) involved in the consultation process and state date agreement obtained. Individual(s) Group(s) Committee(s) Head of IT Interim Assistant Director of Informatics ehealth Informatics Strategy Board Information Governance sub Committee Information Governance Committee Date(s) 23/12/14 18/12/14 Date(s) 09/03/15 Date(s) 13/03/15 RATIFYING AUTHORITY (in accordance with the Schedule of Delegation) NAME OF COMMITTEE IGC KEY A = Approval Required FR = Final Ratification A Date Approval Obtained COMMENTS/ POINTS TO NOTE Date Equality Impact Assessment Undertaken Group completing Equality impact assessment Anthony Tracey Jackie Hooper Sarah Odishow Please enter any keywords to be used in the policy search system to enable staff to locate this policy Information, Informatics, Mobile Working, BYOD, CYOD, Tablet, Smartphone, IT Database No: 422 Page 2 of 11 Version 0.2
3 Document Implementation Plan How Will This Policy Be Implemented? Disseminated via the staff intranet, through communication when employees utilise the scheme and as a part of post induction Information governance training Who Should Use The Document? What (if any) Training/Financial Implications are Associated with this document? All staff that are part of, or wish to be part of, the CYOD / BYOD scheme. None Action By Whom By When Agreement to proceed IGC What are the Action Plan/Timescales for implementing this policy? Ratified IGC Policy active on intranet Active Policy ed to all staff via global Highlight Policy to all staff via ongoing information governance training. IGC Policy Co-ordinator Policy Co-ordinator Information Governance Manger Database No: 422 Page 3 of 11 Version 0.2
4 CONTENTS 1. INTRODUCTION POLICY STATEMENT SCOPE AIMS OBJECTIVES BRING YOUR OWN DEVICE APPLYING FOR THE SERVICE ACCEPTABLE USE RESPONSIBILITIES REIMBURSEMENT SECURITY DATA SECURITY RISKS/LIABILITIES/DISCLAIMERS ROLES AND RESPONSIBILITIES; TRAINING IMPLEMENTATION REVIEW Database No: 422 Page 4 of 11 Version 0.2
5 1. INTRODUCTION The Health Board has the goal to enable greater flexibility to allow the use of Smart phones and Tablets to access Health Board data and applications. These can be both corporately owned devices (Choose Your Own Device CYOD) and personally owned devices (Bring Your Own Device BYOD). This service will allow you to access, Your work Your work calendar Your work contacts A secure work web browser (Access to internal web sites) Citrix based applications Public applications available in App Stores which maybe of relevant to your role Private applications which might be developed in the future by Hywel Dda and/or its partners. work office documents The use of portable devices and mobile platforms is now commonplace in our personal lives and this consumerisation of IT is now spreading into NHS use. For many years laptops and blackberry s have been used to provide remote access to information but the adoption of tablets and smartphones has the potential to deliver many benefits to Health Board staff especially those which are mobile. This mobile device use however poses a substantial risk in that devices may be lost, damaged, or stolen, potentially resulting in loss or inappropriate disclosure of data. When using mobile devices, the risks of working in an unprotected environment must be considered and mitigated where possible by the use of appropriate security systems and the procedures outlined in this policy. 2. POLICY STATEMENT To utilise any of these services to access corporate data and applications, all users of the service must agree to the following terms and conditions before IT can enable the service. This will be communicated in writing over and a record retained. All users of this service will fully comply with corporate policies on appropriate mobile phone, and internet usage. These can be found on the intranet. All users of this service must familiarise themselves with the corporate information governance policies and ensure they are adhered to. All users of this service will need to adhere to the security policies of the Health Board ensuring safe access to corporate data and applications. A security application will provide the Health Board with the ability to lock down and secure the device such as enforcing a password/pass code & encrypting the device. Policies enforced on your device are aimed at managing corporate data and applications, your personal information on BYOD devices will not be affected. Policies on CYOD which are corporately owned will be aimed at managing the device and any personal information on these devices is not permitted to be stored and is done so at your own risk. Database No: 422 Page 5 of 11 Version 0.2
6 HYWEL DDA UNIVERSITY HEALTH BOARD You will keep your password / passcode secret and not allow anybody else to access the information. This will be setup when the device is first registered and will need to be changed at periodic intervals. Should you lose or have your BYOD device stolen you will need to report this to IT immediately so that we can remove corporate data from it remotely. It will be the user s responsibility to report the theft of the device to the police for an incident number. Should you lose or have your CYOD device stolen you will need to report this to IT immediately so that we can wipe the device remotely. The Health Board will then report the theft of the device to the relevant individuals in the Health Board. In the unlikely event that personal data on the BYOD device is affected or lost, HDUHB will not be held responsible or liable for any damages or compensation. Any personal data on the CYOD device will be lost if the device is stolen or lost as the device will be wiped completely. You will inform the HDUHB IT department if you no longer need access to these services, we will remove the app from your device and retire it from the service. You accept that the HDUHB will not be liable for any charges relating to the handset hardware, tariff, insurance, call or data charges incurred when using BYOD devices. You understand the app might interfere with the operation of your phone/ tablet and accept this; examples include enforcing a lock screen passcode / password and encryption. You accept that the HDUHB offers no support or maintenance for the phone/tablet and it is your responsibility to maintain or repair it as and when required for BYOD devices. CYOD will be fully supported by the Informatics Service Desk. No cloud services should be used to store Health Board data such as Apple s icloud, GoogleDrive, Dropbox and Microsoft OneDrive. Separate services are available to enable data to be shared with third parties or for home access. Please contact the Informatics Service Desk to access these. Failure to adhere to these protocols will result in the withdrawal of the service. 3. SCOPE All staff that are part of the scheme or manage staff that are part of the scheme needs to adhere to this policy. 4. AIMS The aims of this policy are: 1. To ensure that the Health Board complies with its legal obligations. 2. To promote the safe and secure use of mobile equipment in support of the clinical and operational work of Hywel Dda University Health Board. 3. To provide a secure working environment for personnel working remotely on corporate / public wireless networks and 2G/3G/4G mobile connections. 4. To ensure that resources provided to staff are not misused. 5. To ensure that the security of mobile systems and the information they contain is not compromised in any way. The policy applies to all full-time and part-time employees of the Health Board, non-executive directors, contracted third parties (including agency staff), students/trainees, bank staff, staff on secondment and other staff on placement with Hywel Dda University Health Board, volunteers and staff of partner organisations with approved access. Database No: 422 Page 6 of 11 Version 0.2
7 5. OBJECTIVES Mobile working must be authorised and controlled by heads of departments / budget holders. The Health Board s approved method of enabling the required security is the mobile device management product called MobileIron. The user will need to input their Cymru username and password which ensures strong authentication. Users will be required to sign a declaration before access is granted. Mobile phones and similar devices used for application / data access must have a security PIN number or passcode enabled. Future Smartphones / tablets will also support Biometric security such as fingerprint / facial recognition. Person identifiable information (PII) or other confidential Health Board data must not be stored on mobile devices or media. Where possible information should be transferred to the Health Board s secure network and deleted from the device as soon as possible. 6. BRING YOUR OWN DEVICE Applying for the service There will be a cost for this service which is viewable on the Informatics Intranet Site. Your manager will need to approve this spend and provide IT with a cost code. Please log a call with the Informatics service desk or use the online form to access the service, which will be in the IT section of the forms library Acceptable Use The Health Board defines acceptable business use as activities that directly or indirectly support the services within HDUHB. Acceptable use for Internet and use is available in the relevant existing policies. For BYOD the Health Board defines acceptable personal use on the organisations time as reasonable and limited personal communication. Devices camera and/or video capabilities will not be disabled but must be used within the relevant Health Board guidelines for handling images. CYOD devices may not be used at any time to: o Store or transmit illicit materials o Harass particularly on the grounds of any protected characteristic as defined in the Equality Act 2010 o Engage in outside business activities A white list of applications will be maintained and these maybe pushed directly to the device on registration. CYOD will have policies applied to ensure a blacklist of applications are maintained so that these cannot be used on Health Board devices. Employees may use their mobile device to access the following Health Board resources: , calendars, contacts, documents, websites and approved applications HDUHB has a zero-tolerance policy for texting or ing while driving. Database No: 422 Page 7 of 11 Version 0.2
8 Devices and Support HYWEL DDA UNIVERSITY HEALTH BOARD Smartphone s including iphone, Android, Blackberry and Windows phones are allowed and a detailed list of supported devices will be maintained on the Intranet. Tablets inluding ipad, Windows and Android are allowed. Connectivity issues are supported by IT; employees should contact the device manufacturer or their carrier for operating system or hardware-related issues for BYOD devices. The BYOD software does support Android but due to the various implementations of the Andriod operating system by manufacturers we cannot guarantee all devices will function as required. NO jail broken or rooted devices are allowed and will be automatically rejected and will not connect to the service. After a licence is purchased and your user account is authorised on the system you will be sent instructions on how to add your device to the service. APP Details The work space is a secure container which enables access to your work , calendar, contacts and a secure work browser. There will also be a work app store where we recommend certain public applications that we feel are useful applications and any apps that have been developed for Hywel Dda. you will have access to work and to lookup users from the directory. Tasks These are sync d with our system Calender These are sync d with our system Secure web browser this will allow access to work web sites e.g. the intranet. Access to work files and the ability to create docs (subject to pending Office 365 implementation) and access to our sharepoint environment under development. There are limitations with the degree of functionality of internal applications. This relates to how the application has been designed to function in a traditional PC/Laptop environment with larger screens. If you still wish to access web applications (such as the Welsh Clinical Portal) or applications via Citrix (HDDAPPS) such as Myrddin CiS, you can do but in the knowledge that full functionality may not be available and navigation may be difficult. 7. RESPONSIBILITIES Reimbursement The Health Boards will not reimburse the employee for a percentage of the cost of the BYOD device. The Health Board will not reimburse the employee for data charges on BYOD devices Security In order to prevent unauthorized access, devices must be password protected using the features of the device and your Cymru password is required to access the Health Board wireless network. Passwords must be at least six number pincode. Passwords will be rotated every 90 days and the new password can not be one of 15 previous passwords. Database No: 422 Page 8 of 11 Version 0.2
9 HYWEL DDA UNIVERSITY HEALTH BOARD The device will lock itself with a pass code or PIN if it s idle for five minutes. After five failed login attempts, the device will lock. Contact IT to regain access. Rooted (Android) or jailbroken (ios) devices are strictly forbidden from accessing the service. Employees are automatically prevented from downloading, installing and using any app that does not appear on Health Boards list of approved apps on CYOD devices For CYOD the device may be remotely wiped if 1) the device is lost, 2) the employee terminates his or her employment, 3) IT detects a data or policy breach, a virus or similar threat to the security of the Health Board s data and technology infrastructure. For BYOD the secure container will be wiped removing Health Board data and applications, personal data will not be affected Data security The work space area is fully encrypted whilst on the device and all data in transit to and from the device is fully encrypted. The device integrity and authenticity is continually checked for any security risks and immediately blocked if detected. The work space is protected with a password/pin and it is your responsibility to keep this safe and we would recommend that you make this memorable and complex. Should you lose the device or you feel the work area could be compromised you must inform the Informatics Service Desk immediately and we will wipe the work area. This will NOT interfere with any personal data of the device for BYOD devices. The mobile device security passcode will wipe the entire device on the tenth incorrect password entry. This will wipe all corporate information and applications on the device (as well as any personal data.) IT do not have sight of the password and cannot recover it Risks/Liabilities/Disclaimers While IT will take every precaution to prevent the employee s personal data from being lost in the event it must remote wipe the secure container on a BYOD device, it is the employee s responsibility to take additional precautions, such as backing up your personal device using the icloud for example. The Health Board reserves the right to disconnect devices or disable services without notification. Lost or stolen devices must be reported to the Health Board immediately. Employees are responsible for notifying their mobile carrier immediately upon loss of a BYOD device. A self service portal will also be available for employees to disable their own devices if required. The employee is expected to use his or her devices in an ethical manner at all times and adhere to the Health Board s acceptable use policy as outlined above. The employee is personally liable for all costs associated with his or her BYOD device. The employee assumes full liability for risks including, but not limited to, the partial or complete loss of company and personal data due to an operating system crash, errors, bugs, viruses, malware, and/or other software or hardware failures, or programming errors that render the device unusable. HDUHB reserves the right to take appropriate disciplinary action for noncompliance with this policy. Database No: 422 Page 9 of 11 Version 0.2
10 Roles and responsibilities; Directors Directors are responsible for the management of information risk within their control and in particular are responsible for ensuring their staff are aware of the information risks identified within this policy and take responsible action to mitigate them. Directors must Ensure procedures are in place within their sphere of responsibility to enable the identification and assessment of information risks of mobile computing and the implementation of control measures, including staff training and awareness to mitigate the risks. Ensure all mobile and teleworkers are appropriately approved and authorised. This should include a procedure to ensure that mobile computing and removable media devices used are approved for Health Board equipment Line Managers Managers are responsible for ensuring that all their staff have read and understood this policy prior to authorising mobile computing arrangements. They must ensure that staff work in compliance with this policy and other appropriate legislation and Health Board policies. This includes the responsibility for ensuring that risk assessments are or have been carried out and that suitable controls are put in place and remain in place to either eradicate or minimise any identified risks to the security of Health Board information All Staff All staff, whether permanent, temporary or contracted, must be aware of their own individual responsibilities for the maintenance of confidentiality, data protection, information security management and information quality and understand they are required to comply with this policy. Failure to comply with this policy may result in disciplinary action being taken, which may result in the withdrawal of authorisation and facility to utilise this scheme. Staff shall inform their manager if they have any concerns about any issues that would constitute an information risk. This covers not only risks to resources or confidentiality of data, but also personal risk, risk to others and risk to the Health Board s reputation. Staff need to confirm to their line manager that they understand this policy and their responsibility for the protection and security of the Health Board information they access. Health Board information must only be used for Health Board related purposes in connection with Health Board work. Staff are responsible for ensuring that unauthorised individuals are not able to see any confidential Health Board information or access Health Board systems. Users of information will: Keep usage to a minimum in public areas Only use information off-site/at home for work related purposes Ensure security of information within the home Not send person identifiable or confidential data to home (internet) addresses Not dispose of any media (including paper) off-site Database No: 422 Page 10 of 11 Version 0.2
11 The use and storage of person identifiable or confidential data on staff owned equipment is strictly forbidden. Staff may only use a Health Board supplied encrypted USB data key for this purpose. 8. TRAINING No training requirements. 9. IMPLEMENTATION Disseminated via the staff intranet, through communication when employees utilise the scheme and as a part of post induction Information governance training. 10. REVIEW This Policy will be reviewed after 3 years, or sooner, as required. Database No: 422 Page 11 of 11 Version 0.2
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