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Tracking Technology Requires Meticulous Policy Planning

By Michael B. Baker / October 19, 2012 / Contact Reporter
Business Travel News on X

Houston - Travel buyers who are assessing traveler-tracking technology should carefully consider policies around usage, according to security experts speaking here this month at HospitalityLawyer.com's Global Congress on travel risk management.

Even as tracking technology through smartphones and other personal devices improves, a successful policy above all should be aware of its limitations, said Charlie LeBlanc, president of security and intelligence at risk management firm FrontierMedex. Despite sales pitches to the contrary, all tracking technology has gaps, he said.

"We've field-tested 10 different technologies, both GPS- and GSM-based, and whether off iPhones, Androids or BlackBerrys, we haven't found a device that works perfectly in all locations, especially on an international basis," LeBlanc said. "Depending on the technology, your results may vary."

Land O'Lakes director of global security Don Taussig, for example, said his organization has a number of employees deployed around the world who are beyond the reach of cell phone technology, in areas including those near the Kenya-Somalia border. For those cases, he said the agricultural cooperative needs alternative plans.

Scheduling regular check-ins through a hotline for travelers in high-risk areas is one solution, Taussig said. A company could require a traveler to check in once a day, for example, then begin a response should they fail to do so.

Even where communications technology works, there is no guarantee that a company will find travelers during a crisis; technology only is as good as how cooperative travelers are in using it.

Companies that take a more open approach to mobile devices by allowing employees to use their own preferred smartphone rather than requiring a company-issued one might face further stumbling blocks. For example, LeBlanc described how a few clients that no longer reimburse mobile device costs but want to install tracking apps are battling disgruntled employee groups.

Kevin Troutman, a partner at the Houston-based law firm Fisher & Phillips, recommended that companies be completely up front with employees about the degree to which they plan to use tracking technology—whether it would be used during working hours, during personal time while traveling on company business or only when the traveler is in a high-risk area, for example. Companies also should ask employees to sign an agreement regarding the policy, he said.

"You may go so far as to have that employee request whether they want to be tracked beyond working hours, and some may say yes," Troutman said. "The right to privacy is not so deeply held in the private sector. But you don't have carte blanche either, so make sure you tell the employees in case you run into a problem where they say they didn't know you were going to be tracking them."

Once policy is set, companies should be sure not to use tracking for other purposes, LeBlanc said. Besides potential legal implications—U.S. laws around employee tracking remain somewhat murky—the effectiveness of the program may be diluted.

"If the purpose of a program is to track employees, you can't turn around and use that technology to bolster a fraud investigation case or see that the employee was visiting a certain vendor that was on a banned list," LeBlanc explained. "The wider the scope you make in that policy, the less you're going to get true participation."

If employees become too leery about employers tracking their whereabouts, they simply might turn off their phones or leave them behind, rendering tracking technology useless. LeBlanc said that's an especially high risk for companies that use "geo-fencing"—automated alerts that notify a company when, for example, an employee enters a particularly unseemly neighborhood of Bangkok.

Programs that inadvertently encourage employees to ditch their mobile devices may increase risks even for travelers in low-risk destinations. "For many of us, that cell phone is literally a lifeline," LeBlanc said. "Try to find a pay phone in Houston. If they leave one communication device sitting in a hotel, it causes more problems than it solves."

Companies also should ensure that tracking and security policies are used consistently across all employee groups, said Land O'Lakes' Taussig. While safety and tracking protocols might vary from region to region, they should apply to all employees in that region.

"If I'm going to provide a service to an expat, I'd better provide it to everyone working there," he said. "From a duty-of-care perspective, you have to treat everyone the same way, no matter their nationality."

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