Employee Data Protection Policy
This document has been updated for compatibility with the UK GDPR. It is ready for use from the start of 2021.
This template Employee Data Protection Policy sets out the rights of data
subjects and the obligations of an employer in its capacity as a data
controller under the UK's data protection legislation (including the UK GDPR and Data Protection Act 2018), setting out a number of organisational and
procedural measures to help ensure compliance.
This template has recently been reviewed and comprehensively updated and
now includes a number of new and more detailed provisions including key
definitions of technical terms, more helpful guidance on obtaining further
assistance, new sections on important topics such as consent, and more
specific provisions on the ways in which employees’ personal data will be
The provisions of this policy are very detailed, reproducing key elements
of the UK GDPR, designed to assist in the data protection learning and compliance process within your
business, particularly with regard to HR. It is still important to note,
however, that training remains essential and that all personnel handling
personal data within your business should be fully aware of the data protection legislation and
its principles, as well as the procedures in place within your business.
The terminology used in this Employee Data Policy limits its context and
applicability to personal data relating to employees. For a more general
data protection policy (for customer data, for example), please refer to
our standard Data Protection Policy, available in the Business document folder.
This document is designed for business use only, and certain provisions of
the UK GDPR relating to public authorities and other official bodies have not
been fully incorporated.
This document is also available in the Business document folder.
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 Employee Data Protection Policy contains the following sections:
4. The Data Protection Principles
5. The Rights of Data Subjects
6. Lawful, Fair, and Transparent Data Processing
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. Personal Data
24. Equal Opportunities Monitoring Information
25. Health Records
27. [Trade Unions]
28. Employee Monitoring
29. Data Security – Transferring Personal Data and Communications
30. Data Security – Storage
31. Data Security – Disposal
32. Data Security – Use of Personal Data
33. Data Security – IT Security
34. Organisational Measures
35. Sharing Personal Data
36. Transferring Personal Data to a Country Outside the UK
37. Data Breach Notification
38. Implementation of Policy
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