Company phone policy template: a reference for businesses

ABMDM Editorial Team. Published: 02/11/2026.

What should a company phone policy cover?

Cover eight things: who owns the device, what it is for, what the company manages, what the company does not look at, when location is viewed, what happens if it is lost, how it is returned when someone leaves, and that a personal phone enters the system only with written consent. The template below follows those points and reflects how ABMDM manages a business's iPhones and iPads.

The template is a reference only and is not legal advice. Before anyone signs it or you add it to your labour rules, have a lawyer or your HR team review it.

Background on privacy when managing devices: staff phone management. The data law from a business's side: Vietnam's 2025 Personal Data Protection Law.

A separate policy or part of the labour rules?

There are two routes, and which one fits is a question for a lawyer. For an employer with 10 or more employees, the 2019 Labour Code requires written labour rules (Article 118, clause 1), according to LuatVietnam's summary. The same summaries say the rules must not conflict with labour law.

If you put the phone policy into the labour rules, those summaries describe further steps (check them against the official text before you act):

• Consult the employee representative organisation at the workplace, if there is one, before issuing or amending the rules.
• Notify employees and post the main content.
• Register with the competent authority; ask a lawyer where to file. The filing deadline is 10 days from issuing the rules (LuatVietnam, registering labour rules). The rules take effect after 15 days, under Article 121 (LuatVietnam, labour rules regulations).

If you keep it as a separate policy tied to the device handover record, you skip those steps, but it still must not conflict with labour law, and employees should sign to acknowledge it. How violations are handled is the sensitive part: the template below leaves it blank on purpose, because discipline must follow labour rules that are in force and labour law.

Sample text: company phone use policy

Reference only. Not legal advice. Ask a lawyer before applying. Square brackets mark what the company fills in.

COMPANY PHONE USE POLICY [Company name], effective from [effective date].

Article 1. Scope. This policy applies to iPhones and iPads the company issues to employees ([list of roles issued a device]). The device belongs to the company. The employee is the person entrusted to hold and use it.

Article 2. Handover. Each device has a handover record showing the serial number, date and recipient. The employee checks the device on receipt and signs to confirm.

Article 3. Purpose. The device is for company work. Personal use is: [company to fill in: allowed / limited / not allowed].

Article 4. What the company manages. The device is enrolled in a mobile device management (MDM) system. The company may: push Wi-Fi, VPN and certificate settings; require a passcode; hide or block certain apps not needed for work; lock the device remotely with a contact number; and wipe the device when it is sure the hardware will not come back. The device is supervised, so the employee cannot remove it from management. The employee must not remove, bypass or ask anyone else to bypass that management.

Article 5. What the company does not look at. The company does not read the employee's messages, photos or passwords on the device. The system records only device information, management status and command history.

Article 6. Location. The company does not track location day to day. Location is viewed only when the device is put in lost mode. Each view is logged: who, which device, when. The employee has been told about this and confirms consent by signing at the end of this policy. People allowed to view location: [company to fill in job titles, as few as possible].

Article 7. Loss or damage. The employee reports a lost or damaged device immediately to [contact person]. The company may lock the device remotely and put it in lost mode. The employee's material liability: [lawyer to fill in, following the labour rules and the law].

Article 8. Leaving, changing roles, returning the device. When the employment contract ends or the employee is no longer entitled to a company device, the employee returns the device, charger and accessories within [number] days. The company records the return, removes the device from management and checks it before returning it to stock or issuing it to someone else. The employee does not sign a personal Apple Account in on a company device without approval.

Article 9. Personal devices. The company does not enrol an employee's personal device in the management system. If an employee wants to use a personal device for work, both sides sign a separate document stating the scope of management, and the company acts only within that scope.

Article 10. Handling violations. [Lawyer to fill in, following labour rules that are in force.]

Employee signature: [full name, job title, date]. Company representative: [full name, job title].

What a lawyer or HR must fill in

The template deliberately leaves four matters blank or unaddressed, because this article has no official source to write them:

1. Handling violations and material liability (Articles 7 and 10): depends on labour rules in force and on labour law.
2. Personal use of the device (Article 3): the company's decision; there is no general answer.
3. Return deadline (Article 8): choose to suit the company. This article gives no number because it has no verified rule for one.
4. Contact outside working hours: the template does not include this clause. If the company needs one, ask a lawyer about working time and rest periods in the labour rules.

Why the template is narrow on location

Location is the data most likely to cause disputes. A Government page quotes Article 31(3) of the Personal Data Protection Law 91/2025/QH15: tracking location requires the data subject's consent, unless a competent authority requires it or another law provides otherwise. Source: Xây dựng chính sách (Government), 30 July 2025.

Whether that provision applies word for word to a company managing its employees' devices, this article does not say. So the template takes the cautious route: tell the employee clearly, record consent with a signature, view location only when the device is lost, and keep a log. The data ABMDM collects is listed on the security page.

An employee's personal phone also does not become a company phone by itself. Enrolling personal phones by link or QR code on ABMDM is still Coming soon and is not part of the service. Until it ships, keep Article 9 as written: do not put a home phone into the system.

Before employees sign: five steps

1. List company devices and who holds them; keep personal phones out.
2. Fill in the blanks and have a lawyer review the final text, especially Articles 7 and 10.
3. Decide whether it goes into the labour rules or stays a separate policy. If it goes into the rules, follow the notice and registration steps above.
4. Decide who in the company may use the dashboard and who may view location; match Article 6. On its security page, ABMDM states that only people with a granted role can view location.
5. Keep the command log. If there is a complaint, it is evidence for both sides.

For the process when someone leaves, check it against Article 8: reclaiming staff phones. To see what ABMDM does for a fleet of company devices: company phone management. To ask how to configure things to match this policy, call 0913 081 986 (8am–9pm).