Rising to the Ethical Challenges of Remote Working
In their Professional Responsibility column, Anthony Davis and Janis Meyer address some of the specific ways the New York Rules of Professional Conduct require particular vigilance in the world of the "new normal" remote workplace.
May 01, 2020 at 03:33 PM
8 minute read
The New York Rules of Professional Conduct (NYRPC) present lawyers with a panoply of obligations in the new world of enforced remote working. Rule 1.1 and its comments exhort us to be technologically competent; Rule 1.3 requires continued diligence; Rule 1.6—which presents lawyers with a host of specific challenges—requires continuing attention to the protection of confidential information; Rule 1.15 requires the safeguarding of client property, from afar; and Rules 5.1, 5.2 and 5.3 present important obligations of supervision on lawyers who supervise others, including support staff. In this article we will address some of the specific ways the Rules require particular vigilance in the world of the "new normal" remote workplace.
Preserving Confidentiality—Using the Internet From Remote Locations. So you've (hopefully) got a nice fast Internet set up at home, and perhaps it's used by others in the household, and provides television and other forms of online escape. But is it secure? If it isn't correctly set up, you may be working in a seriously compromised environment accessible to hackers—or just your neighbors—enabling access to client as well as personal information. Here are some steps you can take to protect your clients' and your own information:
Check your router settings: (1) Make sure you have changed the device's default administrative (internal) password to one that is unique to you and (2) set a strong unique WiFi password (phrases are good) of 15 characters. (3) Change the name of the WiFi network (its SSID)—if you use the manufacturer's default you have effectively established your network as if it were public WiFi). In addition, (4) make sure that the router is using the latest encryption standard (preferably WPA2). (You should be able to find the various manufacturer settings by going to the manufacturer's website.)
Make sure your personal devices are secure: (1) Set your mobile device to lock after a brief period of inactivity; (2) require a separate strong passcode, pattern, fingerprint, or facial recognition capability to unlock it and consider setting a different password/PIN for each device; and (3) keep your device's operating system up to date, which can be done by allowing your devices to automatically accept updates to keep them reliable and protected.
Preserving Confidentiality—Understanding the Risks of Videoconferencing. Those Zoom remote cocktail party or family gatherings are fun, and many of us are getting used to them as the closest substitute available to the in-person contact we crave. On the other hand, you may have read about "Zoom bombing" and other concerns about Zoom and other videoconferencing options in a professional context, and the ethical issues in connection with videoconferencing go beyond any perceived weaknesses of particular providers and solutions. Videoconferences can be prone to hacking or at least loss of confidentiality in a number of ways. For instance, the provider may be able—and in some cases may even have a policy and practice—of gathering personal information about all of the users of the platform (not just the host).
In addition, screen-sharing can create an open door for other users—or hackers—to get into everything on the device you are using. And unbeknownst to you, the conference may be being recorded. How much care you take, or forgo, in a personal setting is not the standard for use where client confidences are involved.
If your firm has a license to use a particular platform, use that whenever possible. Even if you are the host, on a platform approved and licensed by your firm, but especially if anyone other than you is the host of a videoconference, make sure that (1) the recording functionality is disabled; (2) you (and others) do not use any uploading or transfer of documents over the platform, or screen sharing; (3) password protection or other limitations are in place that restrict access to the meeting to those who should be participating; and (4) you consider using code names to prevent any invisible and unwanted attendees from acquiring client or matter identifying information.
Confidential documents should be exchanged outside the setting of the video conference, using secure emails. And, finally, however much the videoconference provides some measure of connection in these difficult days, consider instead using that old-fashioned technology the telephone if significant confidential information is likely to be involved in the conference.
And, it goes without saying that client information should not be placed in a text, if for no other reason than ensuring that there is a reliable record of the communication.
Preserving Confidentiality—Other Technology Risks in the Home Environment. Two other risks need to be recognized and addressed. First, however cumbersome and troublesome it may sometimes be to work only in the secure Citrix or VPN environment, to the maximum extent possible it is important not to download confidential information to home devices outside the firm's network. First, they are susceptible to hacking (which is why the firm network is there in the first place). Second, the confidential information remains on the home device even after the work is completed, and therefore remains there when the device is later disposed of. Notably, this even applies to printing at home (some outside counsel guidelines prohibit it), but it is sometimes impractical for lawyers to work without creating physical documents. And third, and of critical importance when working with others in the firm, working on documents outside the network means that multiple versions are created and it may become impossible later to create an accurate record of what was created for the client.
Second, beware of Alexa, and any other similar "smart speakers." They are always listening. And the companies that sell them to us have admitted that sometimes their staff actually tune in to hear what is going on around the devices. Of course, they stress this is purely for market and research purposes, but even if that is always the case, by speaking about confidential matters when these devices are turned on, lawyers are evidently not observing the requirements of Rule 1.6, or of technological competence under Rule 1.1
Preserving Confidentiality—Physical Security When Working from Home. In some ways, the hardest challenge to preserving client confidences arises from the difficulties of preventing inadvertent disclosure of information on documents being used for working on client matters. Unfortunately, even before all of us had no choice in the matter, there were cases where family members saw material in plain view when lawyers were working at home, and then engaged in insider trading based on what they had seen. But even aside from those egregious breaches, the duty to protect confidential information is serious and must be actively considered. There are important steps that need to be considered to manage this obligation. Ideally, work only in a room used only for that purpose. When, as for most of us, that is not possible or practicable, (1) make sure screens are positioned so as not to be visible to others; (2) keep printed documents in folders when not in active use, and keep the folders in a secure place; and (3) conduct videoconferences (and phone calls) out of earshot of others.
Continue To Supervise. We have focused attention on all the ways in which Rules 1.1 and 1.6 are implicated in the remote working environment. But other professional responsibility obligations are of equally critical importance. Most significantly, the duty of senior lawyers to supervise the work of subordinates comes into play with extra force. And this duty has extra components in the remote environment. Not only must matters and work tasks be overseen, but important human considerations must be recognized and supported, including both the physical and mental wellbeing of the other lawyers in the firm. And care must be given to be ready to have backup arrangements in place for handling work if a member of the team falls ill or requires time for family or other obligations that pop up in this stressful time.
Finally, two points to keep on the virtual radar screen. Apart from the additional hurdles that are present as a result of our new remote set up, the need to identify and manage deadlines—which may be constantly moving because of external disruptions in litigation or in business contexts—remains a vitally important element of managing the practice both to serve clients and avoid claims. And do not lose sight of obligations with respect to escrow accounts and any other client property you are holding. The lawyer's duty to oversee and ensure safekeeping remain constant and may require additional vigilance when administrative personnel responsible for day-to-day oversight are working in remote settings as well.
Anthony E. Davis and Janis M. Meyer are of counsel at Clyde & Co US.
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