Compliance Solutions for Investment Advisers

Do You Have a Mobile Device Policy?

With the proliferation of smart phones, iPads and table computers in the advisory business, I would suggest that all advisers probably would benefit from developing and implementing policies and procedures regarding their use. Here are some issues you should consider:

  • What are employees permitted to access from their mobile devices?
  • If employees have the capability to access nonpublic personal information of clients or confidential firm information, what security measures have been taken to safeguard such information?
  • Can anyone else outside the advisory firm access the information on an employee’s mobile device (e.g., family members, co-workers)?
  • Is the mobile device password protected (or better yet, have a fingerprint scanner)?
  • Does the mobile device have software that would allow it to be remotely wiped clean in the event the device is lost or stolen?
  • What are your firm’s procedures if a device is lost?
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