Feel in need of a new acronym to add to your privacy wardrobe? Well you will be pleased to hear that you now need APDs to sit alongside your RoPs, DPIAs and LIAs.
An APD is an 'Appropriate Policy Document'. This isn't a new requirement but the ICO (oops there's another one) has just released new guidance on special category data and finally published a template APD. You need an APD under the DPA (aggh, too many already!) in the UK in many situations where you are processing special category data (particularly if relying on the substantial public interest provisions or employment, social security and social protection basis ) or criminal offence data.
Until now there was no ICO template for this and many companies have been quite behind on this documentation. Now you have no excuse...