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Data Privacy Concerns: Tips for Teleworking During Coronavirus

By Jarad M. Lucan & William J. Roberts on April 9, 2020
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With the increase in remote work during this COVID-19 outbreak, many organizations are vulnerable to new data privacy and cybersecurity risks.  Now more than ever, even a minor incident can be devastating to a business.  For organizations, we have prepared a Best Practices Checklist with recommended next steps to help your organization manage the risks of teleworking at scale — the most important of which is to communicate with and train your workforce.  For teleworkers, we have put together a Best Practices Checklist to remind employees how important it is to take steps to minimize privacy risks associated with remote work.

Best Practices Checklist for Organizations:

  • Promote a security-aware workforce.  Keep your telework staff informed of common social-engineering attacks and train staff on work-from-home security basics.  Teleworkers should be further trained to recognize situations that require involvement from your organization’s security teams.
  • Review your software-as-a-service products.  Especially evaluate existing collaboration apps and programs, and plan for increases in utilization.  Focusing on the ability for systems to safely handle the increased traffic as well as training your workforce on safe practices (including the potential dangers of sharing a screen) are critical.
  • Review onboarding processes.  Review any existing processes for credentialing new or existing users.  The rush to enable remote work capabilities for existing personnel can create additional security risks during a crisis.
  • Do not trust personnel home-networks.  Plan your telework security policies and controls on the assumption that external environments contain hostile threats.  You cannot rely on personnel to have enterprise level security on their home networks.  Treating each teleworker’s network as unsecured mitigates ongoing risk.
  • Check your policies.  Review or develop your telework security policies to define telework, remote access, and bring-your-own device requirements.  Confirm that your servers are configured in line with these policies.
  • Be cautious about permitting bring-your-own devices.  If your organization permits the use of bring-your-own devices on the organization’s network, consider establishing a separate, external, dedicated network for these users in order to mitigate security risk.
  • Remind personnel of incident reporting procedures.  Ensure clear reporting mechanisms for security incidents.  Personnel should be informed of the value of reporting incidents as soon as possible.  Early discovery mitigates many of the worst consequences of security incidents.

Best Practices Checklist for Teleworkers (and what organizations should be reinforcing):

  • Avoid public Wi-Fi.  If you are unable to access a trusted network for internet access, use your phone as a hotspot.  Public Wi-Fi networks are one of the riskiest ways of accessing the internet.
  • Secure your home network.  Determine if your router has up-to-date firmware and permits secure encrypted communications.  If not, determine if a router upgrade is available.
  • Use work-issued devices.  While you may prefer to use a personal device when teleworking, if possible, use a work-issued device to minimize security and data leakage risks associated with using an unsecured, personal device.
  • Avoid sharing your work-issued device with others in your household.  Telework can break down the barriers between work and home.  Device sharing dramatically increases the risk of unauthorized information sharing.
  • Be security-aware.  Report suspicious emails to your security team and remember that teleworking opens up a new range of social-engineering style attacks.  When calling coworkers on personal phones, always verify their identity through known work-issued communications channels.
  • Keep a clean workspace.  Take care to ensure that work-related papers, particularly those relating to confidential, personal, or customer information, be kept out of view of family members.
  • Lock your screen.  When in a shared workspace or family environment, lock your screen when away from your computer.
  • Dispose wisely.  If you have confidential or sensitive information in paper copy, shred it.  Do not dispose of sensitive information in your household trash.
  • Use company-approved technology platforms. Avoid using email, collaboration and file-sharing platforms that have not been approved by your company’s information security team. When using approved platforms, be vigilant to intruders on tele or web conferences, such as by password protecting sessions or carefully taking attendance.

Your personnel and security teams may request additional guidance on the specific controls and recommendations provided in these checklists.  Please refer them to the following resources.

  • NIST: Bulletin on Remote Work; Guide to Enterprise Telework
  • NCSC: Preparing your organization for home working
  • CISCO Systems: Understanding Remote Worker Security
  • FTC: Online Security when Working from Home

If you have any questions regarding appropriate data privacy and cybersecurity responses to COVID-19, please do not hesitate to contact any member of the Data Privacy and Protection Group at Shipman & Goodwin.

Photo of Jarad M. Lucan Jarad M. Lucan

Jarad is co-chair of Shipman’s Labor, Employment and Education Department, where he practices on behalf of both public and private sector clients.  Jarad has successfully represented employers in grievance arbitration matters, prohibited practice proceedings before the State Board of Labor Relations, and unfair…

Jarad is co-chair of Shipman’s Labor, Employment and Education Department, where he practices on behalf of both public and private sector clients.  Jarad has successfully represented employers in grievance arbitration matters, prohibited practice proceedings before the State Board of Labor Relations, and unfair labor practice proceedings before the National Labor Relations Board.  He has also represented employers in cases involving claims of discrimination and retaliation before the Commission on Human Rights and Opportunities, the Equal Employment Opportunity Commission and State and Federal Courts.

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Photo of William J. Roberts William J. Roberts

William Roberts is the Chair of Shipman & Goodwin LLP’s Privacy and Data Protection team. Bill is also a Certified Information Privacy Professional (CIPP/US) through the International Association of Privacy Professionals (IAPP). Bill focuses his practice at the intersection of privacy, technology and…

William Roberts is the Chair of Shipman & Goodwin LLP’s Privacy and Data Protection team. Bill is also a Certified Information Privacy Professional (CIPP/US) through the International Association of Privacy Professionals (IAPP). Bill focuses his practice at the intersection of privacy, technology and the law, and represents a wide range of public and private entities. He assists clients nationwide in navigating legal challenges with respect to regulatory compliance, governmental investigations, data breaches and complex contracting. Clients who seek Bill’s guidance range from start-ups to Fortune 50 companies.

Aside from helping his busy clients, Bill is a father and lifelong skier.

Bill’s complete biography can be found here.

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Employment Law Letter
  • Organization:
    Shipman & Goodwin LLP
  • Article: View Original Source

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