GDPR Employee Data Protection Policy Template

GDPR Employee 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 current 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 Employee Data Protection Policy template sets out the rights of data subjects and the obligations of an employer in its capacity as a data controller under the GDPR, setting out a number of organisational and procedural measures to help ensure compliance.

This GDPR Employee Data Protection Policy has been reviewed and comprehensively updated as part of our on-going GDPR review of data protection-related content.

The provisions of this policy are 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.

The language used in this Employee Data Protection 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 GDPR Data Protection Policy.

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.

This document is also available in the Employment document folder and in the IT & Software Group under IT & Data Policies.

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 GDPR Employee 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
22. Health Records
23. Benefits
24. [Trade Unions]
25. Employee Monitoring
26. Data Security - Transferring Personal Data and Communications
27. Data Security - Storage
28. Data Security - Disposal
29. Data Security - Use of Personal Data
30. Data Security - IT Security
31. Organisational Measures
32. Transferring Personal Data to a Country Outside the EEA
33. Data Breach Notification
34. Implementation of Policy

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