| Commentary

(4) Policies and procedures

| Commentary

(4)     Policies and procedures

Having written comprehensive policies and procedures in place, keeping them up to date and clearly communicating them to employees (including providing staff training on them) and other data subjects will assist employers in meeting the accountability requirement (see para [194.91]) and to take practical steps to meet their legal obligations. It will also inform employees of what is expected of them when they are processing personal data themselves on behalf of their employer in the course of their employment.

What policies are required, and their level of detail, will vary depending on the employer and

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