The Office of the Information and Privacy Commissioner of Newfoundland and Labrador ('OIPC') published, on 18 September 2017, guidance on travelling with mobile devices for health custodians ('the Guidance'). The Guidance outlines the reasonable safeguards that health custodians should take with regard to personal information stores in employees' mobile devices, in order to comply with the Personal Health Information Act 2011 ('PHIA').

In particular, the Guidance outlines that health custodians develop a sufficient policy regarding travelling while in possession of mobile devices, including to prohibit carrying personal information on such devices in certain circumstances. Additionally, custodians should take various data security measures, including that all data on such devcies in encrypted and minimise the amount of personal information on mobile devices prior to travelling and ensure such data is backed-up electronically.

Moreover, the Guidance explains that custodians must ensure employees are aware that when traveling with personal information on a device of the potential necessity to disclose personal information on it to officials on the Canadian border with the US. As a result, the Guidance recommends custodians prohibit employees from carrying employer issued mobile devices when travelling to the US for personal reasons.

You can read the Guidance here.