The use of new communication technologies has allowed more effective communication both internally and externally of companies [a]. Email, instant messaging, and internal websites are some of the technologies being utilized to effectively correspond within the office. As these technologies are becoming commonplace, employees are more likely to spend significant portions of work time on personal tasks. Employers are becoming concerned that they aren’t utilizing their employees to their full potential and therefore many are opting to use monitoring software to encourage strong work ethics. From 1997 to 2004, the number of employers monitoring email has risen from 15 to 27 percent [h]. By 2004, 56 percent of employed Americans felt that email correspondence should remain private [h]. Employers should establish meaningful relationships as well as trust with their employees instead of relying on spying and lockdowns in order to thwart liability concerns.