GDPR Policy Templates for UK Businesses

Effective policies form the foundation of any organisation's governance system. They have an important role in developing corporate culture, defining acceptable and undesirable practices, and harmonising efforts to achieve the company's goals.

Data protection regulations like the UK GDPR require organisations to maintain certain policies. However, many organisations may find it difficult to create thorough GDPR policies that conform to the strict requirements of the UK GDPR. Without clear guidelines, the process of creating policies can become burdensome and lead to inconsistent procedures, gaps in compliance, and potential liability.

GDPR policy templates assist companies in establishing a uniform approach to data protection. When properly adapted to the organisation's needs, they ensure that all stakeholders in the business understand the organisation's rules and responsibilities relating to data protection.

This blog will highlight the key policies required under the UK GDPR and outline their essential ingredients. We will also include some practical templates to help you get started, so whether you are creating your GDPR framework from scratch or want to revamp your existing policies, you will have the resources you need. 

What is a GDPR Policy Template?

A GDPR policy template is a pre-structured document that outlines the necessary components to comply with the GDPR. It assists organisations in developing clear, comprehensive policies that meet legal requirements. Some policies, such as data protection policies, privacy policies, cookie policies, and so on, are mandatory for UK companies.

Policies impose a duty of care on organisations; therefore, they must be carefully crafted, as mishandling can result in considerable liability. 

In certain circumstances, regulators may use policy violations and non-compliance to hold an organisation accountable. Specifically, in the EU, several data protection authorities, such as the Swedish DPA and the Dutch DPA, have issued fines to organisations due to insufficient privacy policies. The UK's Information Commissioner's Office (ICO) has also issued reprimand to the Home Office and requested they update their internal policies and privacy information. 

Using GDPR policy templates can decrease the risks associated with non-compliant policies. 

Benefits of Using GDPR Policy Templates

A policy template, drafted with legal requirements in mind, ensures that organisations can create policies that meet the stringent requirements of the laws without starting from scratch. Some other benefits include, they;

1. Save time and resources by providing a ready-made framework that an organisation can adapt to suit their requirements and obligations.
2. Reduce the risk of non-compliance and potential regulatory sanctions.
3. Aid in easy understanding and communication of policies since experts often create templates in concise and clear language.
4. Integrate industry best practices and standards.
5. Save costs arising from the need for an extensive legal consultation to draft a policy from scratch.

Different Types of GDPR Policy Templates

Personal Data Protection Policy

A personal data protection policy is an internal document outlining an organisation's data protection approach. It covers how the organisation manages, secures, and processes personal data. 

It helps to ensure compliance with Article 24 of the GDPR and can serve as a tool to demonstrate compliance to regulators.

A data protection policy template should include the following, at least:

• details on the scope and category of personal data processed in the organisation, 
• the principles of data processing, 
• data subject rights, 
• data security measures, 
• data breach incident management, 
• third-party vendor management, 
• international data transfer,
• records of processing activities, 
• data disclosures, 
• data retention, 
• employee responsibilities, and
• training.

Privacy Policy

A privacy policy, also known as a privacy notice or privacy statement, is an external document that explains how an organisation processes personal data.

Stemming from Article 13 of the GDPR, it must be presented to individuals at the time personal data is collected from them and include the following:

• Information about the controller and how to contact them or their representative
• Contact details of the Data Protection Officer
• Purposes of processing and the legal basis for the processing
• Where applicable, the legitimate interest of the controller or a third party
• The recipients or categories of recipients of personal data
• Information about international data transfer
• The data retention period or the criteria for determining data retention
• Rights of individuals

The EDPB has provided a privacy statement template, which can be found here.

Cookie Policy

A cookie policy specifically addresses the use of cookies and similar tracking technologies on a website or application. 

Organisations must provide clear information about the types of cookies used, their purpose, and how users can manage or withdraw consent. 

A cookie policy template should include sections on the types of cookies used, their function and duration, third parties with access to collected data, and instructions for users on how to control cookie settings.

The UK ICO has created a checklist that can assist in auditing the use of cookies on your organisation's website and drafting your cookie policy.

Step-by-Step Guide to Using GDPR Policy Templates

GDPR policy templates provide a foundation for policy creation. They should be considered as the beginning of the journey rather than the end. Below is a step-by-step guide on how to use GDPR policy templates

How to choose the right template

• Identify your business requirements. Understand your business goals and objectives regarding the use of personal data. 
• Understand the types of data your organisation processes and the processing activities conducted with the data.
• Know your organisation's role - whether you are a data controller, processor, or both. 
• Look for templates from reputable sources like the ICO and other Data Protection Authorities. 
• Ensure the templates match your industry requirements to address industry-specific requirements. For example, industries in the financial or health sector may have other requirements that are specific to them and may not be considered in generic templates. 

How to customise your template

A GDPR policy template is not a one-fit-all solution. It would be best to adapt it to fit your organisation's specific processing activities and culture. For example, if your organisation operates in several jurisdictions, the template should be adapted to address the unique requirements of each region. Some specific customisation tips are as follows:

• Ensure the policy is written in clear, easily understandable language that everyone in your organisation can understand. Avoid legal jargon.
• Collaborate with the relevant stakeholders in key departments to ensure that the policy reflects how data is managed in practice.
• Ensure all necessary elements are included in the policy. You may double-check the clauses with a checklist or cross-reference with the GDPR to ensure nothing of importance is missed.
• The policy should be seen as a dynamic and living document. As regulations change or business requirements evolve, the policies should be regularly updated to ensure they are up-to-date. 

Tailored GDPR Policy Templates for Specific Needs

For small businesses

GDPR compliance is for all businesses, regardless of their size. As a small business, you have much to gain by complying with the GDPR. You can easily earn your customers' trust. When customers know that their data is processed securely, they tend to trust and stay loyal to the business. Also, when adequate security measures are in place, compliance can help prevent fraud and cybercrimes. 

Policy templates should be simple, straightforward, and easy to implement. Start with a basic template and remove any overly complex clauses irrelevant to your operations.

Focus on your core activities and customise the template to reflect your data processing activities. For example, if your small business mostly handles customer data for orders and marketing, emphasise these areas in your policy.

Assign clear responsibilities. Although roles may overlap, a responsible person should be determined for data protection-related tasks and specify them in your policies.

For charities

GDPR applies to charities as much as it does to businesses. Given that many charities rely heavily on personal data-driven activities—like fundraising, marketing, and volunteer coordination— the GDPR significantly impacts their operations. Adapting GDPR policy templates to suit a charity's needs requires a focus on the unique aspects of charitable work. Some tips for adapting policy templates include:

• Ensure the policy covers detailed guidance on the processing of special categories of personal data where applicable. 
• Ensure the policy covers the specific needs of different stakeholders, such as donors, volunteers, beneficiaries, and employees.
• Incorporate the ethical considerations (for example, data usage and sharing with other organisations) of the organisation into the policy.

For recruitment

Recruitment agencies and human resource departments process large volumes of personal data from applicants. They process various categories of personal data, including employment history, educational background, and possibly special categories of personal data such as health information and criminal records.

Several policies are useful in ensuring that personal data is processed lawfully, transparently, and securely. They include: 

• Recruitment policy: This policy outlines an organisation's guidelines and procedures for hiring new employees. It should include clear guidelines on obtaining candidate consent, data retention periods, and secure handling of applicant information to prevent unauthorised access or breaches, among other things.
• Applicant/candidate privacy policy: This policy details how an organisation collects, processes, and protects the personal data of job applicants. It should explain what types of information are gathered, how it is used, and applicants' rights regarding their data.
• Employee referral policy: This policy encourages current employees to refer qualified candidates for open positions. It must also cover the handling and disclosing of referred candidates' personal data. 
• Data disclosure policy: This policy governs the conditions under which personal data can be shared within the organisation or with external parties. It should include provisions for data sharing in recruitment, such as with background check providers or recruitment agencies.

Data Protection Statement/Job Applicant Privacy Notice by the United Kingdom's Student Loan Company

Frequently Asked Questions about GDPR Policy Templates

What are the Key Components of a GDPR Policy?

A GDPR policy should;

• define the scope of the business and set clear objectives.
• include the mandatory requirement of applicable data protection laws such as the UK GDPR. 
• be concise, clear and easy to understand. 
• be enforceable, and identify responsible persons. 
• be updated regularly in accordance with the evolving regulations and the organisation's processing activities. 

Can I Use a Generic Template for My Specific Business?

While generic GDPR templates can provide a useful starting point, they must be customised to reflect the organisation's specific needs and risks. Adopting a generic template without tailoring it could lead to gaps in compliance, as it might not address your organisation's unique data processing activities, industry-specific regulations, or your organisation’s operational nuances.

What is the Difference Between a Data Protection Policy and a Privacy Policy?

The Data Protection Policy is an internal document outlining an organisation's approach to GDPR compliance. In contrast, the Privacy Policy is a public-facing document informing individuals about the collection and use of their personal data, their rights and other information on how the organisation handles their personal data.

How Do I Ensure My Policy Template is Compliant with UK Regulations?

• Benchmark the policy template against the requirements of the UK GDPR and other relevant regulations. For detailed information on UK data protection requirements, refer to the ICO's guidance and codes of practice. 
• You can also have your policies audited by data protection experts such as Privasee to ensure they meet all necessary requirements.
• Regularly review and update the policy to reflect any changes in the regulations as well as your business practices.

Best Practices for Implementing and Maintaining GDPR Policies

• Designate responsible individuals (policy owners) to oversee the implementation and maintenance of each GDPR policy.
• Collaborate with relevant stakeholders in key departments to ensure the policies reflect their processing activities.
• Maintain version history/control for each policy to track changes and ensure all stakeholders are aware of the latest updates.
• Ensure all policies are easily accessible to employees, partners, and relevant stakeholders.
• Include GDPR policies in your organisation's annual training and communication strategies to reinforce awareness and compliance.
• Review, evaluate and update policies annually or following significant organisational changes such as when a new product is launched or there is an expansion into new markets.
• Train employees on their responsibilities as it relates to the policies.
• Integrate the policies into everyday business activities by using procedures to operationalise them.
• Automated tools such as policy trackers can be used to monitor and update policies.

Ensuring GDPR Compliance with Effective Policy Templates

Policy templates can be customised to suit your organisation's specific needs and legal requirements while saving time and effort. Using GDPR policy templates provides a standardised way to create important data protection policies that meet GDPR standards.

In conclusion, to achieve the best results, it's important to create and customise policy templates based on your organisation's specific needs.

Additional Resources and Templates for GDPR Compliance

The Data Protection Office, Principality of Liechtenstein, - Templates

The Irish Data Protection Commission - GDPR guidance for SMEs.

EDPB - Cookie Policy

GDPR.eu - Templates

UK ICO - Privacy Notice Generator