"Too often business associates fail to ... [address] risks relating to devices (e.g., smartphones, laptops or tablets) that are owned by employees rather than the covered entity or the business associate....[D]oes your organization require that all portable devices be password protected and encrypted? ... Does your organization have the ability to remotely wipe these devices clean? Do you require employees to register their personal devices with your organization? What happens when an individual is no longer employed by your organization? Can e-mail/system access for former employees be removed remotely? Do you have policies that prohibit employees ... from using unsecured, public Wi-Fi networks?"

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