The very first step is to carry out an audit. The downloadable GDPR template below can help you identify what type of personal data you are holding in respect of an employee but you can also use this template as a guide to other information about customers that you are also holding. Consider where is the data coming from, where is it being stored and where is it going to.
In using the template think about the following and note where this is stored or used:
Consider that key employees with relevant information may sit in:
Once you have identified the data, look and see what type of data this is and whether it falls under the category of “Special Data”.
Special data is:
Personal data that reveals:
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