Elsie Rodas

03-07-2025

Are you protecting employee training data the right way?

Image by microgen via Envato Elements

Training data is personal data. Learn how to apply GDPR principles to protect learning records, reduce risk, and build trust across your workforce

In today’s digital learning landscape, protecting employee training data isn’t just good practice - it’s a legal and ethical imperative.

Whether you operate in health, social care, education, or any regulated sector, you already know your training records contain much more than attendance sheets or certificates. They hold personal information, evidence of compliance, and sometimes sensitive details about your staff’s competence and development.

Under the UK General Data Protection Regulation (UK GDPR), every organisation is responsible for collecting, storing, processing, and sharing this data in ways that respect individuals’ rights and uphold confidentiality. Yet despite the stakes, many teams still feel unsure about how to translate GDPR principles into everyday processes.

In this blog, I’ll explore what GDPR means for employee training data, why it matters, and what practical steps you can take to protect your workforce - and your organisation.

What counts as employee training data?

Before we look at compliance strategies, let’s be clear about what we’re talking about.

Employee training data is any information you keep to record, track, or evidence learning, competence, and development. Examples include:

• Training records (e.g., dates of completion, attendance logs, certification details)
• Assessment results and competency scores
• CPD (Continuing Professional Development) logs
• E-learning progress reports and learning analytics
• Appraisal or supervision records that reference training needs or achievements
• Feedback forms and evaluation surveys from training sessions.

In regulated sectors, this data isn’t a nice-to-have. It provides evidence to regulators - like the Care Quality Commission (CQC) or Ofsted - that your staff are trained, competent, and safe to practice.

Because these records identify individuals, they are classed as personal data - and in some cases, special category data if they relate to health, diversity monitoring, or other sensitive information. That’s why robust GDPR compliance isn’t optional.

Why GDPR compliance matters in learning and development

GDPR (the General Data Protection Regulation) came into force in 2018, transforming how organisations must handle personal data. In the UK, the Data Protection Act 2018 supports UK GDPR to set out clear rules and obligations.

GDPR gives individuals - your employees - specific rights over their data. It also requires your organisation to process data lawfully, fairly, and transparently.

In learning and development, GDPR compliance matters for several reasons:

• Trust - When employees trust that their records are safe, they are more willing to engage in training and share feedback.
• Regulatory expectations - Inspectors expect to see evidence of both competence and data protection compliance.
• Reputation - A data breach can undermine credibility and erode confidence across your workforce and stakeholders.
• Legal risk - Non-compliance can lead to regulatory action, fines, and compensation claims.

At its heart, GDPR is about respecting the dignity of every individual. From my experience working across the NHS, private hospitals, public health, and education, I’ve seen that a culture of trust and transparency is the bedrock of effective workforce development.

The seven GDPR principles for training data

GDPR sets out seven core principles. They aren’t just abstract concepts - they guide how you design your systems, policies, and practices:

1. Lawfulness, fairness, and transparency

• Be clear about why you collect training data
• Provide employees with privacy notices explaining what you’ll do with their information, who will see it, and how long you’ll retain it.

2. Purpose limitation

• Use data only for its intended purpose - such as maintaining compliance, supporting development, and evidencing qualifications
• If you want to use it for any new purpose, you’ll need a lawful basis (and sometimes explicit consent).

3. Data minimisation

Collect only what you need. For example, don’t record more personal details than necessary to confirm training completion.

4. Accuracy

Keep data up to date. If an employee completes refresher training or updates a qualification, make sure your records reflect this promptly.

5. Storage limitation

Don’t hold records indefinitely. Set and follow clear retention policies - and dispose of data securely when it’s no longer needed.

6. Integrity and confidentiality (Security)

Put appropriate measures in place to prevent unauthorised access, accidental loss, or data corruption.

7. Accountability

Be prepared to demonstrate compliance through clear policies, training logs, data audits, and documented processes.

Practical steps to secure your training data

So how do you make GDPR compliance real? Here are practical actions you can implement today:

1. Map your data flows

Document how training data comes into your organisation, where it’s stored, who uses it, and when it’s shared. This mapping exercise can reveal hidden risks and gaps.

2. Set access controls

Not every person needs access to all training records. Define user permissions carefully - so, for instance, managers see only their teams’ data, not organisation-wide records.

3. Use secure systems

Adopt learning management systems (LMS) or training records platforms with strong security features - like encryption, secure logins, audit trails, and auto-expiry of old data.

4. Train your staff

Anyone involved in handling training records must understand their GDPR responsibilities. Regular training helps prevent accidental breaches.

5. Keep data up to date

Review records regularly to ensure accuracy. Archive training data for leavers in line with your retention policy.

6. Be ready for subject access requests

Employees have the right to see their data. You must be able to supply this information within one month.

7. Prepare a breach response plan

Even with precautions, incidents can happen. A clear plan helps you respond quickly and report breaches to the Information Commissioner’s Office (ICO) and any affected individuals as required.

Do you always need consent?

A common misconception is that you always need consent to hold training records. In reality, most processing of training data is lawful under legitimate interests or legal obligations - such as compliance with CQC, Ofsted, or employment law.

However, if you plan to use the data for other purposes - like promoting services or publishing learner testimonials - you must get clear, explicit consent and explain the reasons for collecting it.

Building a culture of trust and accountability

GDPR compliance shouldn’t be treated as a checkbox exercise. It’s an opportunity to show staff that their personal information matters.

When employees trust that their data is secure, they feel respected - and are more willing to participate fully in training and development.

In my own work as a trainer, nurse, and L&D leader, I’ve seen that transparency and accountability create stronger, more engaged teams. This benefits everyone: your staff, your organisation, and the people you serve.

Final thoughts

As digital learning platforms become more integral to workforce development, protecting employee training data will only grow in importance.

Understanding your responsibilities, embedding clear processes, and fostering a culture of respect will help you secure your data, strengthen your compliance, and build a resilient learning environment.

It’s not about achieving perfection - it’s about staying committed to doing better, one step at a time.

Protect your training data and build workforce trust

Your training records hold more than course completions. They hold personal information, competency data, and evidence of compliance.

Keeping that data secure is not just a legal requirement. It is how you build trust, support engagement, and meet regulatory expectations. ComplyPlus™ gives you a secure and compliant way to manage employee training records with user permissions, audit trails, and automated data retention. Our Train the Trainer programmes also include practical guidance on data handling, helping your internal teams embed GDPR principles into everyday training delivery.

When your systems are secure and your staff are informed, you reduce risk and create a safer, more transparent learning environment.