Remote Working 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.
The COVID-19 pandemic made homeworking more common for many businesses. Consequently, a great deal of personal data that would previously have been confined to business premises and systems is now accessed and processed at home.
Data protection law in the UK, in particular the UK GDPR and Data Protection Act 2018, and compliance with that law, is very important. Ensuring that your staff have a good working knowledge and understanding in order to support technical and organisational safeguards is essential.
This Remote Working Data Protection Policy is based on our general Data Protection Policy and includes additional provisions to make it more suitable for remote working. Under normal circumstances, the handling of personal data by employees working from home would not be desirable, but data protection compliance must adapt to the current situation and a practice which remains popular even as many return to their workplaces.
This document template incorporates much detail from the UK GDPR itself in order to raise awareness among your staff. It also sets out a range of steps to be taken, designed to secure and protect personal data, as well as to improve your 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 addressed.
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 to Business folder subscribers in our UK GDPR & Data Protection group.
This Remote Working 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. [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 Remote Working Data Protection Policy 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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