I tend to agree with the idea of a separate document or an appendix to the DP Policy on how special category and criminal data will be processed. I have seen extremely high level ones from central government and other examples where organisations state that existing documentation constitutes the appropriate policy document. I have opted for a separate document, with some practical use for teams handling that type of data in a higher education setting. I don't think there is a right way.
David Willcox
Clio Information Management Limited
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