Mobile and Communications Device Policy

1.0 Purpose: What we want to accomplish

Library and Technology Services (LTS) and the University provides support for mobile devices, phones, networks and other communication devices that are used to conduct University Business. The purpose of this policy is to provide guidelines, parameters, and information and establish rules for the purchase and/or use and management of University owned and personal mobile devices and communication equipment and services.

2.0 Audience & Scope:

This policy applies to all the faculty and staff and other affiliated parties who use mobile computing devices and other communications equipment and networks to access University Information Resources.

3.0 Policy:

The University’s communications equipment and networks, including phones, mobile phones, tablets are provided to conduct official University business. Use of these resources for personal purposes is largely prohibited except for cases that are outlined in the personal use restrictions below. The determination of whether an employee requires a mobile communications device or equipment and the availability of University funding for such support is at the discretion of the employee’s organizational unit management that is at or above the Dean, Vice Provost or Associate Vice President level. If an employee believes that he or she requires a mobile communications device in order to perform his/her duties, he/she must provide a business expense justification that meets the IRS business purpose tests on a Mobile Device Support Form (Exhibit A). LTS has the authority to install software including device and endpoint management tools and or clients on any Lehigh owned mobile device. Mobile communications devices are defined as devices with access plans for connection, such as cell phones and smartphones. Mobile communications devices are allowable only in situations in which the employee’s business needs cannot be accommodated by the use of a phone connected to a standard University extension. Purchase of a mobile communications device merely for the convenience of the employee does not satisfy the IRS business purpose test. Mobile communications devices are not allowable for the purpose of promoting goodwill, boosting morale, providing additional compensation, or attracting prospective employees.

3.1 Personal Use Restrictions

Use of University owned communications equipment for personal business should be severely limited.  Any marginal cost incurred due to personal use must be repaid by the user.

3.2 General Business Purposes and Use

Examples of IRS Compliant business purposes for a Mobile Device or network include:

• the need to contact the employee at all times for work-related emergencies
• the requirement that the employee be available (i.e. “on-call”) to speak with donors, applicants, or students at all times when the employee is away from the office
• the need for business conversations with individuals in other time zones at times outside the employee’s normal work day

A general business need to remain in contact with the University or to monitor ongoing communications related to one’s duties is not a sufficient standard for exclusion from taxes. Without specific evidence that the employee’s job duties meet IRS requirements for a device, the presumption is that all reimbursements and allowances for mobile communications devices are taxable income to the employee.

3.3 Employee Owned Device and Service Plans

University funds may provide a monthly subsidy to employees who meet the above IRS criteria in order to cover the additional business expense that the employee incurs on their personal cell phone plan. Subsidies will be processed as an out-of-pocket reimbursement through the OneCard system. The dollar amount of the allowance should cover the employee’s anticipated additional business-related expenses, including the cost of basic equipment (as defined in advance by the Unit Head in consultation with his or her business manager). Equipment upgrades or usage unrelated to University business use must not be considered. Appropriate subsidy amounts should be set by the organizational Unit Head and should be reviewed on an annual basis. Monthly subsidies should equal the cost of one line under the terms of the current University cell phone contract. Subsidies in excess of this amount should be justified based upon extraordinary business need. The employee’s cell phone bill should be provided at the time the subsidy amount is determined and renewed.

3.4 University Owned Device and Service Plans

University funds may pay for an employee’s mobile communications device and enrollment in the University cell phone plan. University support is limited to the cost of basic equipment (as defined in advance by the Unit Head in consultation with his or her business manager).

Equipment upgrades beyond basic should be paid from personal funds. Plan service levels should be consistent with the employee’s anticipated business use. Departmental management should monitor the cell phone usage and the employee’s business responsibilities at least annually to ensure that the charges are reasonable and that job responsibilities continue to meet the IRS criteria. University-owned devices are property of the University. When the employee separates from the University, or transfers to a different organization within the University, his or her supervisor shall immediately deactivate the employee’s account and the employee must either purchase the cell phone at fair market value or return the equipment to the University.

3.5 Reimbursement For Business Use of a Personal Device

If the employee’s job responsibilities do not regularly meet the IRS criteria for non-taxable University support, but the employee occasionally exceeds his/her base service plan and incurs additional charges as a result of unusual business-related usage, the employee may submit a reimbursement request for the additional charges.

Employees receiving standard subsidies may also submit an occasional reimbursement request when they incur additional usage charges as a result of extenuating circumstances, such as international business travel. A copy of the employee’s service plan bill, detailing the additional charges must accompany the reimbursement request.

3.6 Home Internet

Departments are prohibited from establishing any arrangements for the reimbursement of home internet charges. Special situations may be addressed via the “Exceptions” provision of this policy statement.

3.7 Tablet Devices and Phones

The use of University funds to purchase tablet devices may be allowable with justification of the predominant business need (see Mobile Device Support Form (Exhibit A)). Purchases must follow LTS guidelines for information security and technology compatibility.

Employees are responsible to take reasonable care of their tablet device, securing them at all times. If an employee’s device is lost, damaged or destroyed through negligence, the employee may be required to repair or replace it at their expense, per the discretion of the manager that approved their device. Employees are responsible to immediately report any loss or theft of a University-supported device.

LTS support of personally-owned devices is limited to a cursory diagnosis of hardware/software issues. Device owners are responsible for engaging their cellular service provider and/or equipment reseller for technical assistance. LTS is not responsible for backing up, transferring, or restoring device content on any personally-owned device. 

University-owned devices are property of the University. When the employee separates from the University, or transfers to a different organization within the University, supervisors shall immediately deactivate the employee’s account and the employee must either purchase the cell phone at fair market value or return the equipment to the University.

Tablet devices may not be charged to a grant index unless the device is fully devoted to the project, necessary for the project, included in the approved budget, and approved by the Office of Research.

3.8 Mobile Device Security/Lost or Stolen Devices

Employees have an obligation to use their wireless communications services in a responsible, informed and safe manner, conforming to network and safety practices and following any applicable laws and regulations. Wireless communications are not secure and employees should use discretion in relaying and storing information on their devices.

All mobile devices that store or process Lehigh University confidential information, regardless of whether they belong to or are paid for by the University, must:

• Have a passcode of at least 4 digits
• Have device encryption enabled
• Be configured to self-erase after 10 consecutive bad passcode attempts
• Have remote-wipe capability enabled
• Have a screen lock with maximum of 5 minute inactivity period

Lehigh University owned devices must be running LTS mobile device management technologies. If a device contains export controlled data, the device user must follow the following Export Controls policy (See Exhibit B below).

Pursuant to federal law, whenever the University is sued or reasonably anticipates that litigation may be commenced, it must take actions to preserve all electronically stored information that may be relevant to the claim. This requires the University to suspend the deletion, overriding, or any other destruction of electronic information relevant to the dispute that is under the control of the University. This includes all forms of electronic communications – e.g., email, word processing, calendars, voice messages, videos, photographs, etc. wherever it is stored, including on mobile communication devices. This electronic information must be preserved so that it can be retrieved – if necessary – at a later time in connection with the lawsuit. Consequently, mobile communication devices used to conduct University business whether owned by the University or the individual, may be subject to these preservation rules.

3.9 Other Technology

Fees for WIFI access devices and service fees (ex: Aircard, MIFI) are allowable if purchased for the purpose of conducting University business while traveling. Purchase of accessories and “apps” for University-owned devices may be supported with University funds if integral to the employee’s ability to use the device for its intended business purchase. Accessories for University-owned devices should be purchased through the University cell phone plan in order to benefit from the negotiated discount. Accessories and “apps” for personally-owned devices are not to be purchased with University funds.

4.0 Exceptions:

The University and Library and Technology Services will consider exceptions to the parameters of this policy, based on the need and in the best interest of the University. Providing the exception request does not jeopardize the security of the University's current network or computing environment, any exception request should be initially requested through your department head. 

5.0 Enforcement:

The Vice President of Business Services, the Director or Purchasing and the Chief Technology Officer and delegates will help with enforcing the policy.

6.0 Definitions:

7.0 Reference Documents:

Exhibit A - IRS business purpose tests on a Mobile Device Support Form
Exhibit B - Lehigh University Export Controls Policy

8.0 Additional Contacts: