This compact Employee Data Protection Policy template is designed for use
as an internal policy document and has an HR focus, dealing specifically
with the personal data of employees.
The provisions of this document set out the rights of employees as “data
subjects”, as bestowed by the GDPR, and the employer’s obligations in its
role as a data controller.
This document has been written as a “short-form” alternative to our
standard Employee Data Protection Policy. Most of the central provisions
are fundamentally the same; however, some more detailed elements have been
removed and replaced with references to separate policies.
Please note that this document is designed for HR use and only in a
business environment. The language used throughout establish and employment
focus which makes this template unsuitable for use in other contexts. A
general Short-Form Data Protection Policy is also available. Please also
note that certain provisions of the GDPR 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 Short-Form Employee Data Protection Policy contains the following
3. Data Protection Officer & Scope of Policy
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. Sharing Personal Data
25. Transferring Personal Data to a Country Outside the [UK and] EEA
26. Data Breach Notification
27. Implementation of Policy
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