Mobile Device Policy (BYOD) (OP-POL-002)

1. Objective

The objective of this policy is to establish comprehensive security requirements for mobile devices used to access [Company Name]’s information systems and data, including both company-owned devices and personal devices used for business purposes (Bring Your Own Device - BYOD). This policy ensures that mobile device usage maintains the confidentiality, integrity, and availability of company information, particularly electronic Protected Health Information (ePHI), while supporting workforce mobility and productivity in compliance with HIPAA, HITECH, and SOC 2 requirements.

2. Scope

This policy applies to all [Company Name] workforce members, including employees, contractors, temporary staff, and third parties who use mobile devices to access company information systems, email, applications, or data. It covers all mobile computing devices including smartphones, tablets, laptops, wearable devices, and any other portable computing device capable of storing, processing, or transmitting company information. This policy applies regardless of device ownership (company-owned or personal) and includes both managed and unmanaged device scenarios.

3. Policy

All mobile devices accessing [Company Name] information systems and data shall be subject to appropriate security controls to protect against unauthorized access, data loss, and security breaches.

3.1 Mobile Device Classification and Requirements

Mobile devices shall be classified based on their access to company information and subject to corresponding security requirements.

3.1.1 Device Classification Levels

Level 1 - Basic Access: Devices with access only to email and basic business applications

  • Standard security configuration required
  • Basic mobile device management (MDM) enrollment
  • Passcode/PIN protection mandatory

Level 2 - Standard Access: Devices with access to internal systems and Confidential information

  • Enhanced security configuration required
  • Full MDM enrollment with compliance monitoring
  • Multi-factor authentication required
  • Encryption mandatory

Level 3 - Restricted Access: Devices with access to ePHI or other Restricted information

  • Maximum security configuration required
  • Shall be company-owned devices only
  • Advanced MDM with containerization/app wrapping
  • Hardware-based encryption required
  • Continuous compliance monitoring
  • Dedicated business profile/container

3.1.2 Acceptable Mobile Devices

Only approved mobile device types and operating systems shall be permitted to access company information:

Approved Device Types:

  • Smartphones running iOS [Version, e.g., 15.0] or later
  • Smartphones running Android [Version, e.g., 11.0] or later with security patch level within [Timeframe, e.g., 90 days]
  • Tablets running iPadOS [Version, e.g., 15.0] or later
  • Tablets running Android [Version, e.g., 11.0] or later with security patch level within [Timeframe, e.g., 90 days]
  • Laptops running Windows [Version, e.g., 10] or later with latest security updates
  • Laptops running macOS [Version, e.g., 12.0] or later with latest security updates

Prohibited Devices:

  • The Mobile Device Management (MDM) system shall be configured to automatically block access from devices with modified firmware (jailbroken/rooted devices).
  • Devices running unsupported or end-of-life operating systems
  • Devices with known critical vulnerabilities that are unpatched
  • Personal gaming devices or IoT devices

3.2 Mobile Device Management (MDM)

All mobile devices accessing company information shall be enrolled in the [Company Name] Mobile Device Management system.

3.2.1 MDM Enrollment Requirements

  • All devices shall be enrolled in MDM before accessing company information
  • Device enrollment shall require management approval and IT verification
  • Users shall accept MDM terms and conditions including remote wipe capabilities
  • Device compliance shall be verified before initial access is granted

3.2.2 MDM Security Policies

The following security policies shall be enforced through MDM:

Device Configuration:

  • Minimum passcode/password complexity requirements (shall use 6-digits or more for passcodes, gesture-based authentication is not acceptable)
  • Automatic screen lock after [Duration, e.g., 5 minutes] of inactivity
  • Maximum failed unlock attempts before device lock/wipe
  • Automatic device encryption enforcement
  • Bluetooth and Wi-Fi security restrictions
  • Camera and microphone restrictions for high-security areas

Application Management:

  • Approved application catalog with pre-approved business applications
  • Prohibition of unauthorized application installation
  • Automatic application updates for security patches
  • Application sandboxing and data isolation
  • Mobile application management (MAM) for business applications

Network Security:

  • VPN requirements for accessing internal systems
  • Prohibition of unsecured Wi-Fi networks for business use
  • Corporate Wi-Fi certificate installation and management
  • Network traffic monitoring and filtering

3.3 Bring Your Own Device (BYOD) Program

Personal devices may be used for business purposes under the BYOD program with appropriate security controls and user agreements.

3.3.1 BYOD Eligibility and Approval

  • BYOD participation shall require a formal application and approval process.
  • Device compatibility assessment and security evaluation are required.
  • A signed BYOD agreement is mandatory. This agreement shall explicitly state the user’s consent to the company’s right to enforce all security policies on the device, including the ability to remotely wipe company data and applications.
  • Background check requirements for access to Restricted information
  • Annual device revalidation and security assessment

3.3.2 BYOD Security Requirements

Mandatory Requirements for all BYOD devices:

  • Current operating system with latest security patches
  • Strong device passcode/biometric authentication
  • Automatic screen lock configuration
  • Full device encryption enabled
  • Remote wipe capability acceptance
  • Separation of business and personal data through containerization

Additional Requirements for Restricted Access:

  • Dedicated business profile or secure container application
  • Hardware-based key storage for encryption
  • Regular malware scanning and threat detection
  • Geolocation services for device tracking
  • Prohibition of certain high-risk applications

3.3.3 BYOD Data Separation

Business and personal data shall be kept separate on BYOD devices:

  • Business applications and data contained within managed workspace
  • Personal applications isolated from business environment
  • Separate email profiles for business and personal use
  • Selective wipe capability for business data only
  • Data loss prevention (DLP) controls for business information

3.4 Security Controls and Monitoring

Comprehensive security controls shall be implemented to protect mobile devices and monitor for security threats.

3.4.1 Authentication and Access Controls

  • Multi-factor authentication required for all business applications
  • Single sign-on (SSO) integration where technically feasible
  • Certificate-based authentication for high-security applications
  • Regular authentication credential rotation
  • Privileged access restrictions for mobile devices

3.4.2 Encryption Requirements

  • Full device encryption mandatory for all devices accessing company information
  • Data-in-transit encryption using approved protocols (TLS 1.3 or equivalent)
  • Application-level encryption for sensitive data storage
  • Secure key management for encryption keys
  • Hardware security module utilization where available

3.4.3 Monitoring and Threat Detection

  • Continuous device compliance monitoring through MDM
  • Mobile threat detection and response capabilities
  • Anomalous behavior detection and alerting
  • Network traffic monitoring for suspicious activity
  • Integration with security information and event management (SIEM) systems

3.5 Mobile Application Security

Business applications on mobile devices shall meet specific security requirements.

3.5.1 Application Approval Process

  • All mobile applications must be reviewed and approved before installation
  • Security assessment of applications including code review and penetration testing
  • Vendor security assessments for third-party applications
  • Application risk classification and appropriate controls implementation
  • Regular application security updates and patch management

3.5.2 Application Security Standards

Mandatory Security Features:

  • Local data encryption and secure storage
  • Certificate pinning for network communications
  • Application sandboxing and isolation
  • Secure authentication mechanisms
  • Session management and timeout controls
  • Anti-tampering and runtime application self-protection (RASP)

3.6 Incident Response and Device Management

Procedures shall be established for responding to mobile device security incidents and managing device lifecycle events.

3.6.1 Lost or Stolen Device Procedures

  • All lost or stolen devices must be reported to the IT Security Team immediately, and in no case later than 1 hour after discovery.
  • Remote location and tracking attempts
  • Remote lock and wipe procedures
  • Access credential revocation and reset
  • Law enforcement reporting if required
  • Incident documentation and lessons learned

3.6.2 Device Lifecycle Management

Device Onboarding:

  • Security assessment and approval process
  • MDM enrollment and configuration
  • User training on security requirements
  • Initial compliance verification

Device Maintenance:

  • Regular compliance monitoring and reporting
  • Security patch management and updates
  • Periodic security assessments
  • User training and awareness updates

Device Offboarding:

  • Complete data wipe and sanitization
  • MDM unenrollment and access revocation
  • Certificate and credential removal
  • Device return procedures (company-owned devices)
  • Exit interview and security debriefing

3.7 Privacy and Legal Considerations

Mobile device usage shall balance security requirements with workforce privacy rights and legal obligations.

3.7.1 Privacy Protection

  • Clear communication of monitoring capabilities and data access rights
  • Separation of business and personal data on BYOD devices
  • Limited monitoring to business-related activities
  • Data minimization principles for collected information
  • Secure disposal of personal information upon employment termination

3.7.2 Legal and Compliance Requirements

  • Compliance with employment law and privacy regulations
  • Data retention and legal hold requirements for mobile data
  • Cross-border data transfer restrictions and compliance
  • eDiscovery procedures for mobile device data
  • Documentation of security measures for audit purposes

4. Standards Compliance

This policy is designed to comply with and support the following industry standards and regulations.

Policy Section Standard/Framework Control Reference
All HIPAA Security Rule 45 CFR § 164.308(a)(4) - Information Access Management
3.4.2 HIPAA Security Rule 45 CFR § 164.312(a)(2)(iv) - Encryption
3.4.2 HIPAA Security Rule 45 CFR § 164.312(e)(1) - Transmission Security
3.4.1 HIPAA Security Rule 45 CFR § 164.312(a)(1) - Access Control
3.4.3 HIPAA Security Rule 45 CFR § 164.312(b) - Audit Controls
All SOC 2 Trust Services Criteria CC6.1 - Logical Access Security
3.4.2 SOC 2 Trust Services Criteria CC6.7 - Data Transmission
3.6.1 SOC 2 Trust Services Criteria CC7.1 - System Monitoring
3.2, 3.4 SOC 2 Trust Services Criteria CC6.3 - Access Management
All NIST Cybersecurity Framework PR.AC-1 - Access Management
3.4.2 NIST Cybersecurity Framework PR.DS-1 - Data Protection

5. Definitions

Bring Your Own Device (BYOD): A policy allowing employees to use personal devices for business purposes.

Containerization: Technology that separates business and personal data on mobile devices.

Jailbreaking/Rooting: The process of removing software restrictions imposed by the device manufacturer or carrier.

Mobile Application Management (MAM): Software that secures and manages business applications on mobile devices.

Mobile Device Management (MDM): Software that manages, monitors, and secures mobile devices across the organization.

Mobile Threat Detection (MTD): Security technology that identifies and responds to threats targeting mobile devices.

Remote Wipe: The ability to remotely delete data from a mobile device.

Sandboxing: Security mechanism that separates applications and prevents them from accessing unauthorized data.

6. Responsibilities

Role Responsibility
IT Security Team Develop mobile security policies, manage MDM systems, monitor device compliance, and respond to mobile security incidents.
IT Support Team Assist with device enrollment, provide technical support, manage device lifecycle, and maintain MDM configurations.
Privacy Officer Ensure mobile device usage complies with privacy requirements, oversee BYOD privacy protections, and manage privacy impact assessments.
Human Resources Integrate mobile security requirements into employment agreements, conduct security training, and manage BYOD program participation.
Legal Team Review mobile device agreements, ensure compliance with employment law, and manage legal aspects of device monitoring and data access.
Security Incident Response Team Respond to mobile security incidents, coordinate device recovery procedures, and conduct incident investigations.
Business Unit Managers Approve mobile device usage for their teams, ensure workforce compliance with mobile security policies, and support incident response activities.
Device Users Comply with mobile security requirements, maintain device security configurations, promptly report security incidents, and participate in security training.
Application Owners Ensure mobile applications meet security requirements, coordinate application security testing, and manage application lifecycle.