Data Protection Policy for Home Working
26 November 2023 Update: This document has been reviewed and updated for compatibility with the UK-US Data Bridge and other “partial findings of adequacy” relating to specific organisations, legislation, and frameworks.
The COVID-19 pandemic ushered in a new era of home working. Even now, as more and more employees return to their normal workplaces, home working remains popular in the UK, and a great deal of personal data that would previously have been confined to business premises and business systems will be accessed and processed in employees’ homes. Having a suitable Data Protection Policy in place that factors in such extraordinary conditions is therefore key.
Data protection compliance is essential in business, and in light of the UK GDPR it is very important to promote good knowledge and understanding among your staff to support technical and organisational safeguards.
This Data Protection Policy for Home Working is a detailed document. It builds on our standard Data Protection Policy, adding a number of useful provisions to make it more suitable for WFH. Under normal circumstances, the handling of personal data by staff working from home is not desirable in many cases, but data protection compliance has been forced to adapt to the change in working practices necessitated by the COVID-19 pandemic that remain widespread even as vaccination and booster programmes allow people to return safely to the workplace.
This Policy template includes considerable detail from the UK GDPR in order to assist in the learning and awareness process throughout your business. It also sets out a range of measures to be followed designed to secure and protect personal data, as well as to improve your business’s compliance with the law.
Please note that this document is designed for business use only, and certain provisions of the law relating to public authorities and other official bodies have not been fully incorporated.
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 to Business folder subscribers in our UK GDPR & Data Protection group.
This Data Protection Policy for Home Working contains the following sections:
1. Introduction
2. Definitions
3. Scope
4. The Data Protection Principles
5. The Rights of Data Subjects
6. Lawful, Fair, and Transparent Data Processing
7. Consent
8. Specified, Explicit, and Legitimate Purposes
9. Adequate, Relevant, and Limited Data Processing
10. Accuracy of Data and Keeping Data Up-to-Date
11. Data Retention
12. Secure Processing
13. Accountability and Record-Keeping
14. Data Protection Impact Assessments and Privacy by Design
15. Keeping Data Subjects Informed
16. Data Subject Access
17. Rectification of Personal Data
18. Erasure of Personal Data
19. Restriction of Personal Data Processing
20. [Data Portability]
21. Objections to Personal Data Processing
22. [Automated Processing, Automated Decision-Making, and Profiling]
23. [Direct Marketing]
24. Personal Data Collected, Held, and Processed
25. Data Security – Transferring Personal Data and Communications
26. Data Security – Storage
27. Data Security – Disposal
28. Data Security – Use of Personal Data
29. Data Security – IT Security
30. Organisational Measures
31. Transferring Personal Data to a Country Outside the UK
32. Data Breach Notification
33. Implementation of Policy
This Data Protection Policy for Home Working is unlocked and in .doc format. Either enter the requisite details in the highlighted fields or adjust the wording to suit your purposes.
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