Businesses in the United States and around the world are currently operating in unprecedented times due to COVID-19. Many businesses have had to become innovative and flexible. Possibly one of the biggest changes to how businesses function from day-to-day is the large number of employees working remotely. Remote work is not new, but many businesses have had to figure out how to transition their employees to working remotely. This transition brings many challenges, but one of the challenges that might be overlooked is document management.
 
Regardless of where you work, at home or in an office, it is important to have a document management policy in place and to communicate with your employees of what that policy is. Here are some things to keep in mind when developing a document management policy for employees working remotely:
 
• Security;
• Personal data and privacy compliance;
• Access to and storage of documents; and
• Disposition and destruction of records.
 
Security
Security is a major concern for companies when transitioning employees to remote work. Employers may need to look into making sure their networks are more secure. VPN, or virtual private network, allows employees to have access to sensitive information from outside the business – this is done through encryption and authentication. Unfortunately, criminals have used the coronavirus as an opportunity to exploit businesses, and employees need to be extra cautious to protect their devices and information from cyberattacks and breaches. It is good practice to shut off VPN when it is not in use. Employers should also communicate the importance of using a secured internet connection versus public Wi-Fi.
 
Personal Data and Privacy Compliance
It is the responsibility of each employee to protect confidential information from misuse or breach, this includes personal data as well as intellectual property. Working remotely may present new challenges to keeping this information secure. Remind employees to be aware of their surroundings when working remotely, whether in their homes or in a public space. Employees should not leave computers, devices, and documents unattended – these devices should be stored so that they are not easily accessible or stolen. Remote work may also lead to an increase in phone and video conferences, thus employees should be aware of eavesdropping, including through personal devices that operate using voice commands.
 
Another consideration when developing a document management plan is the use of personal devices for company business as these devices may not provide the level of privacy that is required for certain types of records.
 

Access to and Storage of Documents

In order to establish good workflow and productivity for employees working remotely, they need to have access to company records. Establishing policies for access and storage of documents is essential. Some questions to consider:
• Who should have access to records?
• What types of records are being created?
• Where should records be stored/saved? Desktop? Shared-storage and cloud locations?
• Should employees save documents to their personal devices?
• Should employees be able to take home hard copies of documents? Where should these be stored?
• Should employees be able to print documents at home?
• When sharing records for collaboration purposes, how should these records be shared?

Working remotely may also change the way in which employees work and collaborate leading to the creation of new records that a business may not have had the need or use for in the past. Collaborating remotely will likely create an influx of emails, instant messages, videos from conference calls, etc. and having a clearly defined policy is an important consideration when developing a document management plan.

Disposition and Destruction of Records
Employees should be directed in how to dispose of their company’s records. These records should not simply be thrown in the trash or recycled. Here are a few things to consider:
• What should employees do with documents printed or created at home? Should they be retained until they can be returned to the office?
• If documents that were printed at home can be disposed of or destroyed, how should they be disposed of or destroyed?
• One of the pitfalls of working remotely is the ability to save records to multiple devices, creating duplication of records. What is the policy for disposing of duplicate or redundant records that may have been saved to multiple devices?
• Lastly, know your company’s retention periods for how long to keep certain records.
 
Whether working remotely is temporary or your company plans to implement future remote work, having a document management plan in place before disaster strikes will help provide a sense of certainty in uncertain times. Contact Zasio to find out how we can help develop a document management program that ensures compliance with security and privacy standards for employees working remotely.

 

Disclaimer: The purpose of this post is to provide general education on Information Governance topics. The statements are informational only and do not constitute legal advice. If you have specific questions regarding the application of the law to your business activities, you should seek the advice of your legal counsel.