An important aspect of managing data protection within your organisation is having a clear understanding of how you plan on managing data protection risk. A data protection policy will help your organisation to define how it will approach data protection and provide colleagues with a clear outline of what is expected of them when data protection issues arise.
There is no standard content for a data protection policy, but it should include high-level principles and rules for your organisation, and it might refer to the procedures and practices, such as data breach or subject access request procedures, but it will not replace these procedures.
Some suggestions of what to include in your policy:
- Your organisation’s approach to data protection
- How the principles will be met
- How the rights of data subjects are protected
- How you will ensure that processing is lawful
- Governance of data protection and responsibility for oversight
- Role of the Data Protection Officer (if required)
- How your organisation demonstrates its accountability
- How technical and organisational measures ensure security
- How staff will be trained and supervised
- How data processors are to be selected
- Obligations of staff to integrity and confidentiality
This is not a complete list and there may be overlaps with other policies, so it is best to ensure that all policies are reviewed in line with any changes.
Finally, it is imperative that policy is clear and understandable ant that all staff read and understand it regularly.