HR Insights • 10 MIN READ
Understanding GDPR for HR Departments
APR 2, 2026
HR departments handle sensitive personal data every day. Here is a plain-language guide to GDPR obligations and how to stay compliant.
GDPR basics for HR
The UK General Data Protection Regulation (UK GDPR) and its EU equivalent govern how personal data is collected, stored, used, and deleted. For HR departments, personal data includes everything from a job application to a payslip to a sickness record. The six data protection principles are lawfulness, fairness, and transparency; purpose limitation; data minimisation; accuracy; storage limitation; and integrity and confidentiality. HR must be able to demonstrate compliance with all six.
Legal bases for processing employee data
Every HR data processing activity must have a legal basis. The most common for employees are: performance of a contract (processing payroll data to pay an employee), legal obligation (maintaining right-to-work records), and legitimate interests (monitoring email use on company devices for security purposes). Special category data, which includes health information, racial or ethnic origin, and biometric data, requires an additional condition: most commonly explicit consent or necessity for employment law purposes.
Employee rights you must honour
Employees have the right to access their personal data (subject access requests must be responded to within one month), the right to have inaccurate data corrected, the right to erasure in some circumstances, and the right to restrict processing. Establish a clear process for handling these requests, train your HR team to recognise them, and ensure you can retrieve the relevant data from your HRIS quickly. Late or incomplete responses can result in regulatory action.
High-risk areas for HR
Certain HR activities carry higher data protection risk: automated decision-making in recruitment (using AI to screen CVs), the transfer of employee data to third-party payroll providers, the collection of biometric data for time-and-attendance systems, and the use of employee monitoring tools. Conduct a Data Protection Impact Assessment (DPIA) before implementing any new technology that processes special category data or involves automated decisions affecting individuals.
