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Home > Resources > HR compliance > Employee privacy > GDPR and data protection > Processing special category personal data and criminal records data policy
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Processing special category personal data and criminal records data policy

This model policy sets out how an organisation processes special category personal data and criminal records data, including the safeguards and lawful bases required under UK GDPR. It helps employers meet their obligation to maintain an appropriate policy document and handle sensitive data lawfully.

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By Jo Broadbent

Use this model policy to comply with the obligation to have an appropriate policy document in place when processing special category personal data and criminal records data. The policy complies with the UK General Data Protection Regulation (UK GDPR).

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  • Letter wording
  • How to use this document
  • Supporting guidance for this document
    • Key resources
    • Notes
  • Future developments

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About the author

Jo Broadbent

Counsel Knowledge Lawyer, Hogan Lovells

Jo Broadbent is a counsel knowledge lawyer in the employment team at law firm Hogan Lovells. In addition to keeping clients and the team up to date with legal developments, she has extensive experience of developing and presenting internal and external client training courses and workshops.

Jo is a former chair of the Employment Lawyers Association training committee. She is a co-author of the book “Informing and consulting employees: the new law” and frequently writes articles for the HR and legal press. She has a particular interest in shared parental leave and other family-friendly rights.

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