POL-U3000.05 Managing Wireless Devices

The Chief Information Officer has overall responsibility for oversight of the policy and procedures. The daily implementation of the policy and related procedures is delegated to the Assistant Vice President for Human Resources.

When official business cannot be accommodated effectively without the use of a wireless device, a supervisor may determine, as resources allow, that a wireless device is essential for a valid business need such as the requirement for an employee to be readily accessible, to improve customer service, enhance business efficiency, or provide safety and/or security.

If an employee is required to carry a wireless device, the supervisor will determine whether it is in the best interests of the University to provide the employee with an allowance to apply towards his/her personally owned service plan and device or use a department purchased device. All determinations are to be based only on job function(s) and departmental need, not by individual job title and will be documented on the Wireless Service Communications Agreement.

Allowances for employee owned devices may only be approved for permanent employees. Exceptions to this requirement may be made by the appropriate Vice President or the President.

Upon approval of the Chief Information Officer, departments may purchase wireless devices and service plans for departmental use when operational needs do not necessitate a device to be assigned full time to an individual employee.

Such devices are University property and the department is responsible for the cost and complying with contract obligations of service plans.

Personal Use of Department Owned Wireless Devices Is Prohibited

Use of department wireless devices is restricted to University business use only, including security and safety situations. Personal use of University owned phones may result in the individual being taxed for the total value of the device and service in accordance with IRS regulations.

Department Heads Are Responsible for Ensuring Review of Calls

Department heads must implement internal review procedures to ensure appropriate use of department wireless devices including auditable documentation.

Employees Responsible for Lost, Stolen or Damaged Wireless Devices

Employees are responsible for the security and maintenance of devices. If a department owned device is lost or destroyed through the employee’s willful misconduct, the supervisor may require the employee to replace it at the employee’s expense. Employees must:

1. Notify their supervisors, as soon as possible but no longer than five working days, of significant damage to, loss or theft of the device, and
2. Comply with Reporting Loss of University Funds or Property Policy (POL-U5950.19).

Security for a Department Owned Device

A security passcode is required to gain access to a cellular device that holds University data. The cellular device must be wiped remotely when the device is lost or stolen.

Employees required by their supervisor to use a personally owned device will receive a service plan allowance through payroll on a semi-monthly basis.

Supervisors will determine an allowance amount that:

1. Is directly linked to the employee’s official duties and responsibilities,
2. Considers an appropriate number of plan minutes, data plans, and other features necessary only to fulfill the job responsibilities, and
3. Is within the tier limits outlined on the Wireless Service Communications Agreement.

Exceptions for allowances outside the tier limits require approval by the appropriate Vice President (or President when applicable). The allowance may be changed and/or withdrawn by the University at any time.

The supervisor may approve a reimbursement for a device and accessories only when the official business required of the employee cannot be accommodated by the employee’s current device. Employees will be reimbursed for a device according to the reimbursement limits stated in the Wireless Service Communications Agreement. If the employee desires a more expensive device and/or accessories for personal reasons, the additional cost is the responsibility of the employee.

A completed Wireless Communications Services Agreement between the supervisor, employee and department director or chair (or Vice President or President when appropriate) is required prior to the provision of any reimbursement or allowance.

Employees approved for an allowance are responsible for enrolling in or transferring ownership of the service plan. Employees are encouraged to consider purchasing service plans available from vendors offering employee discounts.

The employee must select a service plan and device that, at a minimum, meets the business need for which the allowance and reimbursement has been approved. Fees for additional plan or device features not required for University business are the employee’s responsibility.

The employee is responsible for complying with any contract he or she personally signs with a communication service provider, including payment of all expenses incurred.

Upon a determination that a service plan is no longer necessary to meet business needs, and the employee chooses to retain the current service plan for personal reasons, the employee will bear all future costs of maintaining or changing the service plan.

Conversely, if it is determined that a service plan is no longer necessary to meet business needs which are not owing to misuse of a service plan or device, or termination of employment for cause, and the employee chooses not to retain the service plan, the department shall bear any change of service costs.

The employee shall bear the costs associated with service plan changes that are the result of misuse of a device or plan or termination of employment for cause regardless of whether the employee chooses to retain the service plan.

Paid allowances and reimbursements issued under this policy:

1. Are subject to payroll tax withholdings,
2. Do not qualify as compensation for retirement contribution purposes,
3. Do not constitute an increase in base pay, and
4. Are not included in calculations for increase to base pay or establishment of base pay related benefits. Departments will be charged the employer portion of any resulting increased social security taxes associated with this benefit.

When requested by a supervisor, employees must provide a monthly bill/statement that includes total taxes and fees paid by the employee for the service plan. The employee should black out all non-work related activity on each bill to demonstrate the amount of business use. If the documentation does not support the allowance amount, the supervisor may discontinue or adjust the allowance amount. An employee who believes that the monthly bill/statement submitted does not adequately reflect average use may submit additional statements to prove normal business use.

Employees receiving an allowance should be aware that such records are subject to Washington State public disclosure statutes.

Departments are required to retain records for both employee and department owned wireless devices as follows:

1. Employee Owned – Copies of the bills reviewed (as required in section #10 above) are to be available/accessible to the department for six years after the end of the current fiscal year.
2. Department Owned – Department retains records of purchase and use in conformance with the University Records Retention Schedule (based on payment methods).

The department head will review wireless device needs at least annually in order to determine whether department owned devices and employee monthly allowance amounts should be maintained, changed, or discontinued.

When changes to allowance amounts are necessary, the department will immediately complete a new Wireless Communications Services Agreement.

Any wireless device and/or service costs including allowances and reimbursements which are to be directly charged to a sponsored project must be specifically included in the grant proposal and budget justification to be approved by the sponsor. If not included, approval must be obtained from the sponsor by submitting a request through the Office of Research and Sponsored Programs.

Drivers should avoid the use of electronic devices while operating a state vehicle. Electronic devices include but are not limited to cell phones and portable video/music players. In accordance with RCW 46.61.667 and 46.61.668, except as noted below, drivers operating moving motor vehicles are prohibited from using hand held wireless communication devices held to their ear; and from reading, writing or sending text messages while driving, except to report illegal activity, summon emergency help, or to prevent injury to persons or property.

Exception: The prohibition does not apply to drivers of authorized emergency vehicles, tow trucks responding to disabled vehicles, or drivers using hearing aids.

The University reserves the right to monitor activity representing public records on all wireless devices used for University business purposes. An employee’s personal data as defined in RCW.42.56 and University Policy U5400.05(4) is not subject to public disclosure.

Wireless devices may not be used to defame, harass, intimidate, or threaten any other person. Employees are prohibited from using wireless devices in an inappropriate, illegal, illicit or offensive manner. As with any misuse of public resources, employees may be subject disciplinary action up to and including termination.