Cell phone donations show need for coordinated policy, technical and HR safeguards

The following is a guest post by LB3 partner Kevin DiLallo, whose practice includes a specialty in the negotiation of enterprise wireless service contracts.

Putting mobile devices with far more independent intelligence than the regular desk phone into the hands of thousands of employees has always carried the risk of unintended consequences. Society as a whole now practically considers cell phones and smartphones as traveling personal transaction machines, leading to increasing public discussion about using mobile devices for personal and civic purposes.

All of that is highlighted by the wireless industry's successful campaign to raise money for Haitian relief by allowing subscribers to send contribution pledges via text message. This phenomenon has raised over $22 million to date for the American Red Cross. But it's also put telecom managers who issue corporate-liable devices in a tough spot, as large numbers of holders of those devices have effectively pledged funds on the company's dime.

Yet this dilemma simply reflects two recurring issues in enterprise procurement of wireless devices: (1) whether to hold employees accountable for personal use of wireless devices; and (2) how best to employ technical solutions to curb unauthorized uses of those devices.

There are actually many reasons for a company to require employees to account for their personal use of company-subsidized wireless service and devices. One is the arcane, but still in force, IRS recordkeeping and reporting rules for company-issued cell phones. Another is to discourage personal use of company assets that could cut into the employee's normal work routine.

And of course, your company has a purely economic interest in preventing the diversion of corporate funds to unauthorized, personal uses while not appearing as uncaring to your employee base.

Going forward, it's probably easier to simply use technical measures to prevent such personal uses of company-issued mobile devices from the get-go, rather than leaving the door open for such use and then trying to recoup the cost of employees' personal use after the fact. For this reason, we often advise clients that an internal company policy regarding "acceptable use" of company-issued cell phones, while a good idea, is not self-enforcing, and needs to be backed up by technical safeguards.

For programs that allow subscribers to bill fees or donations through their monthly wireless bill -- i.e., using their cell phone like a credit card -- enterprise customers can prevent such costs from showing up on their bills in the future simply by asking their national account reps to block all texting to short codes from corporate-liable devices. Ordinary SMS messaging should be unaffected, but promotions accessed via short codes -- which often entail fees -- will be out of reach of corporate-liable subscribers, at least from the devices their employers subsidize.

But for right now, in the wake of the Haitian crisis, it might be helpful to coordinate with your human relations, public relations and/or corporate giving departments to craft a comprehensive message to employees about why messages are being blocked, and to state any position about both corporate and employee participation in humanitarian relief and alternative ways to contribute.

Short code SMS messages are just one example of the many uses of wireless technology that could increase enterprise subscribers' costs and distract employees from their day-to-day responsibilities. Other examples, all of which can be blocked upon request, are video and music downloads, voice calls to 900 numbers and directory assistance, ringtones, and wallpaper. And for security purposes, enterprises might also consider disabling the camera functions on devices equipped with cameras.

One thing's for sure: Your employees will be asked to reach for their cell phones many times in the future by forces outside your company's control. So this is an ideal time to be coordinating your wireless policies with technical safeguards and good, positive employee communications that acknowledge both their corporate obligations and desire to be good citizens. It's another example of the growing general management challenges of the corporate telecommunications function, and it's something we're continuing to follow closely.