Appropriate policy document

This is the ‘appropriate policy document’ (APD) for Newcastle-under-Lyme Borough Council that sets out how we will protect special category and criminal offence data when the council seeks to rely on any of the following conditions specified in Schedule 1 of the Data Protection Act 2018 (DPA 2018):

  • paragraph 1 - condition for processing in connection with employment, social security or social protection
  • except as otherwise provided in Part 2, any substantial public interest condition (i.e. paragraphs 6-28)
  • paragraph 35(1) – condition for processing in connection with a conviction or caution for child indecency offences specified in paragraph 35(2)

The content of this appropriate policy document meets the requirements of paragraph 39 of Schedule 1, in that it:

  • explains the council's procedures for securing compliance with the principles in Article 5 of the UK General Data Protection Regulation (UK-GDPR) (principles relating to processing of personal data) in connection with the processing of personal data in reliance on the condition in question
  • explains the council's policies regarding the retention and erasure of personal data processed in reliance on the condition, giving an indication of how long such personal data is likely to be retained

In accordance with paragraph 40(1) of Schedule 1, where the council processes personal data in reliance on a condition described in paragraph 38 of Schedule 1, they will during the relevant period:

  • retain the appropriate policy document
  • review and (if appropriate) update it from time to time
  • make it available to the Information Commissioner, on request, without charge