The written policy the Data Protection Act 2018 requires before you rely on most Schedule 1 conditions to use health, diversity, biometric or criminal records data – including for employment, safeguarding and equality monitoring.
Data protection & GDPR
Appropriate Policy Document (Special Category and Criminal Offence Data)
About this document
Most businesses that hold sickness records, occupational health information, diversity monitoring data, DBS results or similar must have an “appropriate policy document” (APD). It explains which Schedule 1 conditions you rely on, how you meet the data protection principles for this data, and how long you keep it. Without one, much of your processing of this data may be unlawful.
The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.
Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.
Included in the pack
Data protection & GDPR
for every document in this category
Editable Microsoft Word files
Guidance notes in every document
Written for UK businesses
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