Whether you’re a UK-based SME or a multinational, having a clear and effective data protection policy is a critical step toward complying with the UK GDPR (General Data Protection Regulation) and DPA (Data Protection Act) 2018, the EU GDPR, and other privacy laws in 2025.
A well-written policy not only protects your organisation against regulatory penalties but also helps build trust with customers, partners, and employees – demonstrating that you take privacy and data security seriously.
What is a data protection policy?
A data protection policy is an internal document that outlines how your organisation collects, processes, stores and protects personal data. It supports accountability under Article 5(2) of the GDPR and may be requested by regulators during audits or investigations.
Unlike a public-facing privacy notice, this policy is primarily intended for employees, contractors, and internal stakeholders.
Why do you need a GDPR data protection policy?
GDPR enforcement has intensified, not declined. Organisations are under increased scrutiny for how they handle personal data, especially with the rise of AI, Cloud services and remote work.
A data protection policy is your first line of defence in demonstrating proactive compliance, especially during audits or breach investigations. It also helps translate GDPR requirements into clear responsibilities for your team.
Who should write and maintain the policy?
Typically, the responsibility falls to the DPO (data protection officer) or, if the organisation has no DPO, a senior individual in compliance, legal or IT. Collaboration with HR, IT and operations is crucial to ensure the policy reflects real-world practices.
The policy should be reviewed at least annually or whenever significant changes occur in data handling practices.
What should a GDPR data protection policy include?
Your policy should be tailored to your organisation’s structure and operations. At a minimum, include:
- Purpose and scope
Outline what the policy covers and who it applies to. - Definitions
Clarify terms like personal data, data controller, processor, and special category data. - Lawful basis
Identify the lawful bases you rely on for processing personal data. - GDPR principles
Address the six data processing principles (lawfulness, fairness, transparency, etc.) and accountability. - Data subject rights
Explain the rights granted under the GDPR and how you fulfil them. - Roles and responsibilities
List the DPO or responsible staff and their contact information - Data security
Briefly describe how you secure data (technical and organisational measures). - Retention and deletion
Include or link to your data retention schedule. - Third parties and transfers
Explain how data is shared with processors or across borders. - Breach response
Summarise your reporting and escalation process.
Common pitfalls to avoid
- Using generic templates without customisation.
- Overlooking Cloud services or remote work practices.
- Failing to align policy language with actual procedures.
- Not updating the policy as your business evolves.
How to make your policy effective
- Use clear, plain English where possible.
- Integrate the policy into onboarding and annual training.
- Keep a record of employee acknowledgements.
- Store the policy in a central, accessible location for all staff.
GDPR data protection policy template
Putting all the necessary information into a policy is a tough task, which is why some organisations simply adapt their existing data protection policy to include GDPR-specific elements.
We don’t recommend this approach, because you can easily overlook essential requirements.
However, we understand the desire for help, which is why we offer a GDPR Data Protection Policy Template.
With this document, designed by our expert information security practitioners, you can create a GDPR-compliant data protection policy in minutes.
A version of this blog was originally published on 6 February 2018.
The post How to Write a GDPR Data Protection Policy (Updated for 2025) appeared first on IT Governance Blog.
