MOBILE TELEPHONES POLICY & GUIDELINES 1 PURPOSE The purpose of this policy is to: Implement a uniform and consistent approach to providing mobile telephony devices for WA Health official communications; Ensure that users of WA Health funded mobile telephony are aware of their responsibilities; and Provide guidelines to assist users with the safe and ethical use of WA Health funded mobile telephony. This policy is an adjunct to the WA Health Acceptable Use Standard Information Communications and Technology (ICT), which defines the acceptable behaviour required of users of WA Health ICT resources. 2 SCOPE This policy applies to all officers (employees, contractors, students, volunteers and agency personnel) within WA Health entities including: Department of Health; Metropolitan Health Services; and WA Country Health Service. This policy addresses mobile telephone devices and services including voice and data services. This policy must be read in conjunction with the Telephone Diversion Policy. Use of other mobile devices is covered by the Mobile Computing Devices Policy and Guidelines 3 POLICY 3.1 Mobile telephones must only be allocated to WA Health officers with a genuine demonstrable business need. 3.2 Requests for advanced smartphones and data services must be authorised by the relevant State Executive Forum (SHEF) member or their nominated delegate and will only be allocated to WA Health officers who can demonstrate a genuine business need. 3.3 The Health Information Network s (HIN) is Service Delivery Directorate is responsible for the purchase of mobile telephone device and services Version: 1.5 Effective Date: 1 August 2011
on behalf of the Metropolitan Health Services and the Department of Health, and will charge the costs to the relevant health entity. WA Country Health Service (WACHS) will be responsible for the purchase of mobile computing devices in line with WA Health purchasing guidelines. Purchases will be in accordance with the WA Department of Finance Common User Agreement (CUA) for Telecommunications. 3.4 WA Health officers must accept full responsibility for using their WA Health mobile telephone in an honest, ethical, safe and legal manner and with regard to the rights and sensitivities of other people. Users must comply with the Acceptable Use Standard. Officers who are supplied mobile telephones for WA Health purposes are responsible for the security of the physical device and any health information stored in the telephone and its storage media. Lost or stolen telephones must be reported as directed by the guidelines. Mobile telephone use must be in accordance with WA Health policies and all relevant federal and state legislation (e.g. privacy, freedom of information, telecommunications and occupational health and safety). WA Health must be reimbursed for personal usage charges. More cost-effective communications such as land lines and e-mail should be used wherever possible. 3.5 In certain circumstances and only with the authorisation by the relevant State Health Executive Forum member or their nominated delegate, privately owned mobile telephones may be permitted to be used for WA Health purposes that requires accessing the WA health Network and/or usage costs reimbursed. HIN sets the conditions under which these devices are permitted to be used (section 4.5). 4 GUIDELINES 4.1 Authorisation Allocation and purchase of a mobile telephone with the standard feature set must be authorised by the relevant Divisional Head / Executive Director. The standard feature set is: voice communications; message bank facility; call diversion; and Short Messaging Services (SMS) Allocation and purchase of a mobile telephone containing advanced features (e.g. data services, web services) and any licenses required for the use must be approved by the relevant SHEF member or their nominated delegate. Printed copies are not controlled 2/10
Officers requesting access to a mobile telephone must submit an Authority & Request for Telecommunications Equipment form to the HIN Service Delivery Directorate. The form includes a business case section for justification for advanced features and smartphones. Management should regularly review the rationale for allocation of mobile telephones, including approvals for replacement of lost or damaged units. 4.2 Allocation Criteria WA Health entities may only allocate mobile telephones to personnel with demonstrable business need. The provision and ongoing use of mobile telephones is to be based on a range of operational criteria including, but not limited to, the following: Duties involving an ambulatory, itinerant or field role with communications requirements; Executives, senior staff and officers who need to be contactable at short notice; On-call duties, particularly involving direct patient care; Time critical situations (e.g. emergency services, emergency management, incident management); Cost effective situations where mobile telephone costs can be demonstrably offset against efficiency gains (e.g. preventative maintenance); Personnel safety requirements; or As deemed necessary by the WA Health entity in order for officers to fulfil their duties. 4.3 Procurement Purchase of handsets or network services may only proceed when the completed Authority & Request for Telecommunications Equipment form has been received by the Service Delivery Directorate, HIN. A copy of this form is to be retained by Service Delivery Directorate, HIN for audit purposes. Procurement of all mobile telephone services (hardware and network carrier) shall be in accordance with the Department of Finance contracts and guidelines. 4.4 E-mail Synchronisation For e-mail/calendar/contacts synchronisation, WA Health has implemented Microsoft ActiveSync and BlackBerry Enterprise Server. There are licenses associated with these services, the purchase of which must be approved and funded by the relevant Divisional Head/Executive Director. If a device is reported lost or stolen, WA Health will erase all data on the device. 4.5 Privately Owned Devices The use of privately owned mobile telephones for WA Health e-mail, calendaring and contacts use is only permitted where: Printed copies are not controlled 3/10
1. Prior authorisation for work use has been obtained from a SHEF member or their nominated delegate, 2. The private device supports Microsoft ActiveSync; and 3. The SHEF member or their nominated delegate approves the purchase of required licenses. HIN reserves the right to set and alter the conditions under which the private devices may be used for WA Health purposes. These conditions include the following: Except where an industrial award has provisions for reimbursement of mobile telephone costs for employer initiated on-call or contact requirements, the user will bear all costs associated with the use of the private device including work related use; HIN may specify minimum acceptable device specifications; HIN may require the private device to be loaded with HIN specified or supplied software for information security purposes to protect WA Health s infrastructure and information. Such software may affect the performance of the device but HIN will not take responsibility for any adverse impact on the private device. Should the device has been mislaid, lost or stolen, the software may provide HIN with the capability to lock the device or destroy data held on the device (including private data held on the device); HIN will maintain a register of the private devices including personal ownership information; The user will be responsible for the protection of WA Health s information (e.g. e-mails) stored on the private device. This includes the removal of such information from the device when the device is disposed of or is transferred to another person. Where the private device containing WA Health information needs to be repaired or left with a third party, the information must be removed; Where the mobile telephone is used to hold WA Health information such as e-mail, the information must be protected by password control at a minimum; and HIN does not offer support for private devices. 4.6 Privacy and Confidentiality Mobile telephone features such as photography or voice recording, have the capacity to infringe on the privacy of others. Users are requested to ensure that the privacy of all visitors, patients and staff etc. is respected. This means that recording and transmitting of images and audio files of individuals must only be done with the specific consent of the individuals or the consent of the carers of the individuals. Communications made via mobile telephones are not necessarily secure, and care should be taken when communicating confidential information. Note that identifying and contact information of third parties stored in mobile phone address books may also be considered private. Printed copies are not controlled 4/10
Where smartphones are authorised for WA Health e-mail use, officers must not use e-mail to communicate confidential or private information unless the information is encrypted. 4.7 Acceptable Use of Mobile Telephones Mobile telephones are provided to officers for work-related purposes. Use of WA Health resources is governed by the Acceptable use Standard. WA health mobile telephones are not to be used for: Conducting private commercial activities Party political or campaigning purposes Access to fee incurring information services for unofficial or unnecessary purposes. Limited personal use is permitted subject to officers reimbursing identifiable personal use costs to WA Health. Officers must not download or store on WA Health mobile telephones any software that has not been legitimately acquired. Mobile telephones are not to be used where a cheaper fixed line service is accessible. Officers need to be aware that their call times and types may be monitored. Officers may be required to explain any excessive use and charges. Inappropriate or unreasonable use of WA Health telephone facilities will require the officer to refund the amount relating to such calls. Officers may also be subject to disciplinary action and other punitive measures as appropriate through legislation such as the Public Service Act and Regulations and the Criminal Code. 4.8 Personal use There may be circumstances where private use is warranted or unavoidable. Officers are expected to be reasonable and responsible in their use at all times. Charges for personal use must be reimbursed as outlined below. By signing the Mobile Telephone Authority & Request for Telecommunications Equipment form, officers also accept responsibility for payment of personal call costs. WA Health entities must put in place procedures for mobile telephone users to sight and sign-off telephone bills or call records issued by service providers, and reimburse the WA Health entity for any personal use charges. 4.9 Use When Operating a Motor Vehicle The amended Regulation 265 (effective 1 March 2011) of the Road Traffic Code 1 restricts the use of mobile phones while the vehicle is moving, or is stationary but not parked. Officers should familiarise themselves with the relevant aspects of the Road Traffic Code. 1 http://www.mediastatements.wa.gov.au/pages/default.aspx?itemid=135862 Printed copies are not controlled 5/10
Options available to drivers of vehicles include: Switching the telephone off Diverting the telephone to a carrier network service message services and retrieving messages at the conclusion of the journey Use of a hands-free kit. Where prolonged in-vehicle use of a hands-free mobile telephone is required, it is recommended that the vehicle be parked in a designated legal parking place. The payment of fines issued for inappropriate use of a mobile telephone will be the responsibility of the driver. 4.10 Electromagnetic Emissions and Radiation (EME/EMR) Australian mobile telephones must comply with the Australian Communications and Media Authority (ACMA) EME exposure standards. In all mobile telephones, radio frequency (RF) or electromagnetic energy (EME) is emitted by both the handset and the antenna. Refer to the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) for advice in which people can reduce their exposure to the electromagnetic fields produced by wireless telephones. These include: limiting call time, preferring use of land-line phones, using hands-free or speaker options and texting instead of making voice calls. Use of the phone in good signal areas will also usually let the phone communicate with lower power levels and further reduce exposures. ARPANSA has also recommended parents encourage their children to use these methods of reducing exposure. 2 Officers may request allocation of hands free attachments (microphone and earpiece) or hands free car kits to reduce mobile telephone proximity while in use. Other actions which may reduce the exposure to RF/EME are: Not utilising a mobile telephone when an alternative means is available (i.e. fixed wire telephone) Reducing the frequency of use and duration of calls Using mobile telephones in an open area, so that the telephone transmits at a lower level Fully extending the antenna if an antenna is fitted. 4.11 Medical Equipment Interference (EMI) Mobile telephones have the potential to interfere with the operation of electromedical equipment. Refer to the guidelines issued by WA Health s Biomedical Engineering services (Operational Circular 0470/94) Hazard Alert Mobile Telephones and Two-Way Radios. The guidelines recommend that mobile telephones be switched off in designated areas such as operating theatres, critical care units, general wards and other treatment areas. 2 ARPANSA Media Release 3 June 2011 Printed copies are not controlled 6/10
The operational circular also advises that visitors and patients should be reminded through appropriate signage that their mobile telephones are to be switched off when in areas other than designated mobile telephone usage areas such as patient lounges, day rooms and amenities areas. Patients using infusion pumps or other mobile medical equipment should be advised to take care when entering designated mobile telephone usage areas. In general ward areas officers should set an example to patients and visitors by limiting their use of mobile telephones to emergency situations only. Clinical staff who need to use mobile telephones in highly instrumented areas should maintain a minimum of 1 metre from medical equipment. 3 4.12 Mobile Telephone Care Officers have an obligation to use their allocated mobile telephone in a responsible, informed and safe manner. Officers are responsible for the security of the devices at all times and may be held liable for any negligence resulting in lost, stolen or damaged units. Mobile telephones should not be left in vehicles or in the office unattended. In the event of a mobile telephone being lost or stolen: Report the loss to the relevant carrier advising that a mobile telephone has been lost and request the service be barred from outgoing calls Report the loss to the HIN Service Delivery Directorate and relevant business unit, and in the case of WACHS to the local IT Manager. If stolen, also report the incident to the WA Police Department, and obtain an official report number for insurance purposes Any unreasonable delay in reporting the loss, which results in misuse of the mobile telephone, may contribute to the officer being held responsible for any costs or damages. 4.13 Hygiene Studies indicate that mobile telephone devices may be contaminated by community and hospital acquired bacteria, and devices used in clinical settings should be subject to infection control practices. 4 4.14 Invoices and Charges The charges for the mobile telephone device, licenses, accessories, call and services costs will be charged to the officer s cost centre. Account management procedures must be established to ensure mobile telephone accounts are closely monitored and any inappropriate use identified and resolved with the user immediately to instil practice that is compliant with this policy. The user is responsible for identifying personal use and reimbursing the relevant WA Health entity for the personal costs including GST. 3 4 ECRI Institute Health Devices December 2006 Brady RR, et al. Review of mobile communication devices as potential reservoirs of nosocomial pathogens. J Hosp Infect. 2009 Apr; 71(4) Printed copies are not controlled 7/10
4.15 Monitoring Mobile telephone usage should be periodically reviewed for compliance with this policy with a view towards assessing that: Assigned mobile telephones are being used responsibly WA Health funds are only being expended on work related charges Personal calls are identified by the user and the reimbursement process followed. Where mobile telephones are allocated on a shared basis (e.g., pool telephone, on call, etc), the management process should include maintaining records of allocation and implementing procedures for all such officers to complete Conditions of Use agreements. Mobile telephones no longer required for business use must be returned immediately to HIN Service Delivery and in the case of WACHS to the local IT Manager for re-allocation or retirement. 4.16 Central Inventory A register of all approved mobile telephones will be maintained by HIN Service Delivery and in the case of WACHS by Regional ICT Managers, and will include the following information: Officer's Name Location (branch/section) Mobile number Make / model IMEI number Carrier Type of Plan Date of connection. In addition, officers issued with a mobile telephone are required to record their phone number in the Internal (electronic) Telephone Directory. 4.17 Disposal All mobile telephones which are to be decommissioned and disposed of must be returned to HIN Service Delivery and in the case of WACHS to their local ICT Manager, for sanitisation and safe disposal in accordance with the Disposal of ICT Equipment Policy 5 IMPLEMENTATION Chief Executives and Executive Directors are responsible for ensuring that all officers within their areas/directorates adhere to this policy. All mobile telephone allocations are to be reviewed annually in accordance with this policy. All new requests for additional or replacement mobile telephones will be assessed against this policy. Where current mobile telephone allocations are no longer deemed appropriate, devices must be returned to HIN Service Delivery Printed copies are not controlled 8/10
Directorate and in the case of WACHS to their local ICT Manager immediately and the service terminated. An audit of the central register will be conducted by HIN Service Delivery Directorate on an annual basis, with a summary report and recommendations for efficient and accountable ongoing management of mobile telephones to be submitted to the Chief Information Officer. 6 BACKGROUND Mobile telephones are integral business tools within WA Health and are used throughout business units across the organisation. Mobile telephones allow officers to manage communications efficiently, especially when they are outside their normal office environment (e.g. when travelling interstate or otherwise off-site). Access to and use of mobile telephones needs to be properly managed in a safe, secure, efficient and accountable manner and in accordance with public sector requirements. 7 ASSOCIATED WA HEALTH POLICIES, STANDARDS AND GUIDELINES Associated WA Health ICT policies are available on the Health Information Network Strategy intranet site: Acceptable Use Standard Mobile Computing Devices Policy and Guidelines Disposal of ICT Equipment Policy Useful reference sites are ECRI Institute Australian Communications and Media Authority (ACMA) Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) 8 RELEVANT LEGISLATION AND GOVERNMENT POLICIES Public Sector Management Act 1994 (WA) Telecommunications Act 1997 (C wlth) Department of Finance CUA 56808 Telecommunications 9 REFERENCES Useful reference sites are ECRI Institute Australian Communications and Media Authority (ACMA) Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) Printed copies are not controlled 9/10
10 VERSION CONTROL Effective Date: Operational Directive No: SHEF ICT Approved Date: 1 August 2011 OD0337/11 April 2011 Responsible Group: Health Information Network - Strategy Enquiries Contact Manager ICT Policy Last Reviewed Date: Version Notes 2011 April v 1.5 Covers smartphones and amendments to the WA Road Traffic Code Regulation 265, effective 1 March 2011, governing use of mobile phones and visual display units while driving. 2009 March previously Mobile Telephones and Wireless Handheld Devices Policy. Printed copies are not controlled 10/10