Employee Data Protection Policy
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.
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 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.
The provisions of this policy are highly detailed, aiming to reproduce key parts of the UK GDPR in order to assist in the data protection compliance and 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 data protection legislation 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 standard Data Protection Policy.
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.
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 for Employment folder subscribers in the HR Policies & Forms group.
This Employee Data Protection Policy 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. Personal Data
24. Equal Opportunities Monitoring Information
25. Health Records
26. Benefits
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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