Older versions of Android can be remotely reset by Google if the company is issued with a court order, but only if they're locked using a pattern.
This is according to a document prepared by the New York District Attorney's Office which revealed just how easily investigators could see the contents of a device.
Devices running Android 5.0 and newer cannot be remotely reset as they use full disk encryption.
However, this option is not switched on by default.
The report found any device using an older version of the operating system is vulnerable to remote reset and according to the Android Developer Dashboard, this is 74.1 per cent of Android devices currently being used.
However, this figure is slightly misleading.
The remote reset feature does apply to phones running operating systems before Android L, but it only applies to people how have secured their device with a pattern.
Google can't remotely reset phones secured with a PIN or passcode, meaning the number of affected devices could be lower.
A post from Google's Adrian Ludwig attempted to clarify the situation.
He said: 'Google has no ability to facilitate unlocking any device that has been protected with a PIN, Password, or fingerprint.
'This is the case whether or not the device is encrypted, and for all versions of Android.
'Google also does not have any mechanism to facilitate access to devices that have been encrypted (whether encrypted by the user, as has been available since Android 3.0 for all Android devices, or encrypted by default, as has been available since Android 5.0 on select devices).
'There are some devices that have been configured to use a "pattern" to unlock. Until Android L, "pattern" unlock did provide a recovery option with the Google account.
'This recovery feature was discontinued with Android L.
'Also, the lost pattern recovery feature never applied to PIN or Password so if you are on an earlier model device and don't want to use the pattern recovery feature, you can switch to a PIN or Password and it will be disabled.'
However, the report insists that forensic examiners are able to bypass passcodes on devices using a 'variety of forensic techniques.'