Appropriate policy document (APD)

What is an Appropriate Policy Document (APD)?

An Appropriate Policy Document (APD) is a document that provides evidence of compliance with data protection principles, particularly within the context of processing special category data or criminal conviction/offence data under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA 2018).

Special category data is data that's considered more sensitive and thus needs more stringent protection, like data concerning health, race, sexual orientation, religious beliefs, etc.

What are the benefits of creating an APD?

1. Compliance with Legal Obligations: The primary benefit of an APD is that it ensures businesses comply with legal obligations under GDPR and DPA 2018 when processing more sensitive data types. This can prevent potential legal disputes, fines, or sanctions.
2. Risk Management: By thoroughly examining and documenting the reasoning and safeguards behind sensitive data processing, businesses can mitigate potential data protection risks, leading to a decreased chance of data breaches or misuse.
3. Transparency and Trust: By making the APD available to relevant parties or stakeholders, a business can demonstrate its commitment to data protection. This transparency can lead to increased trust among customers, partners, and employees.
4. Operational Clarity: An APD can serve as a reference point for employees, ensuring they understand the proper procedures and safeguards for processing sensitive data. This clarity can reduce mistakes and improve overall operational efficiency.
5. Consistency in Data Handling: An APD ensures that all departments or divisions within an organisation follow the same standards and procedures when dealing with sensitive data, leading to consistency and predictability in data handling.
6. Evidence for Accountability: Under GDPR, organisations need to not only comply with data protection principles but also demonstrate that compliance. An APD serves as concrete evidence of a business's adherence to data protection principles.
7. Stakeholder Engagement: Creating an APD might require consultation with various internal and external stakeholders, like data subjects, data protection officers, or third-party partners. This engagement can provide valuable feedback, insights, and potentially lead to better data processing practices.
8. Foundation for Training: The policy can serve as a foundational document for training new employees or retraining current ones, ensuring they understand the principles and practices behind sensitive data processing.

In essence, an Appropriate Policy Document helps businesses navigate the complexities of processing sensitive categories of data, providing a structured approach to ensure both legal compliance and the respect of individuals' rights. It acts as both a guide and evidence of a business's commitment to rigorous data protection standards.