GDPR Data Protection Policy Template

GDPR Data Protection Policy


Data protection has long played a key role in business, and as a result of the GDPR, which came into force on 25 May 2018, it has become even more important. The GDPR expands on the previous regime established by the Data Protection Act 1998, setting out a number of important principles governing how personal data is collected, held, and processed by organisations.

This template Data Protection Policy sets out the rights of data subjects and the obligations of a business as a data controller under the GDPR, setting out a number of organisational and procedural measures to help ensure compliance.

As part of our review of GDPR-related content, this policy has received several updates including clearer provisions on technical data protection measures, new detail governing “special category” personal data (known as “sensitive personal data” under the Data Protection Act 1998) and new references to our Data Retention Policy.

This Data Protection Policy is highly detailed, aiming to reproduce key parts of the GDPR in order to assist in the GDPR learning process throughout your business. Nevertheless, please note that training remains essential and that all personnel handling personal data within your business should be fully aware of the GDPR and its principles, as well as the procedures in place within your business.

This document is designed for business use only, and certain provisions of the GDPR relating to public authorities and other official bodies have not been fully incorporated. Please also note that this is a “living document” and will be reviewed as more best practice and official guidance on the GDPR becomes established.

Optional phrases / clauses are enclosed in square brackets. These should be read carefully and selected so as to be compatible with one another. Unused options should be removed from the document.

This document is also available in the IT & Software group under IT & Data Policies.

This GDPR Data Protection Policy contains the following provisions:

1. Introduction
2. The Data Protection Principles
3. The Rights of Data Subjects
4. Lawful, Fair, and Transparent Data Processing
5. Specified, Explicit, and Legitimate Purposes
6. Adequate, Relevant, and Limited Data Processing
7. Accuracy of Data and Keeping Data Up-to-Date
8. Data Retention
9. Secure Processing
10. Accountability and Record-Keeping
11. Data Protection Impact Assessments
12. Keeping Data Subjects Informed
13. Data Subject Access
14. Rectification of Personal Data
15. Erasure of Personal Data
16. Restriction of Personal Data Processing
17. [Data Portability]
18. Objections to Data Processing
19. [Automated Decision-Making]
20. [Profiling]
21. Personal Data Collected, Held, and Processed
22. Data Security - Transferring Personal Data and Communications
23. Data Security - Storage
24. Data Security - Disposal
25. Data Security - Use of Personal Data
26. Data Security - IT Security
27. Organisational Measures
28. Transferring Personal Data to a Country Outside the EEA
29. Data Breach Notification
30. Implementation of Policy

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