UK vs US templates: what maps, what doesn't
UK and US workplace law are built differently — statutory rights and ACAS codes on one side, at-will employment and OSHA on the other. Here is every UK template and its US counterpart side by side, plus the documents that only exist in one country and why.
Health & Safety
Company Policies
Data & Privacy
| 🇬🇧 UK template | 🇺🇸 US counterpart |
|---|---|
| Data Breach Response Procedure | Data Breach Response Procedure |
| Data Retention & Disposal Policy | Data Retention Policy |
HR & People
Operations
Onboarding
Five UK family-leave policies become one US document
The UK grants separate statutory rights for maternity, paternity, adoption, shared parental leave, and time off for dependants — so each has its own policy. US federal law has no paid-leave equivalent: the FMLA provides unpaid, job-protected leave that covers these situations in one framework (with state paid-leave programs layered on top). That is why Maternity Leave Policy, Paternity Leave Policy, Adoption Leave Policy, Shared Parental Leave Policy, Time Off for Dependants all map to the single FMLA & Family Leave Policy.
🇬🇧 UK statutory only — no honest US equivalent
We could have generated US versions of these. We didn't, because the underlying law doesn't exist in the US and a lookalike template would be misleading.
Written Statement of Employment Particulars — A UK statutory right under the Employment Rights Act. US employment is at-will; the offer letter covers the equivalent ground.
Flexible Working Policy — The statutory right to request flexible working is UK law. US arrangements are contractual — covered by the Remote & Hybrid Work Policy.
Privacy Policy — Written around UK GDPR. The US has no federal GDPR equivalent — state privacy laws (California and others) differ too much for one safe template.
Data Protection Policy — UK GDPR-specific. US data obligations are a state-by-state patchwork plus sector rules.
Subject Access Request (SAR) Procedure — Subject access is a UK GDPR right. Some US states grant similar rights, but the procedures differ per state.
Privacy Notice for Employees — A UK GDPR transparency requirement with no federal US equivalent.
Cookie Policy / Website Notice — Built on UK PECR/GDPR consent rules; US cookie practice is driven by different state laws.
🇺🇸 US-native additions
Documents that exist because of how US workplaces and regulators operate — no UK counterpart needed.
This mapping is general information, not legal advice. UK reasons reference UK statute; US notes reference federal law, and state and local requirements vary. Have anything you rely on reviewed by a qualified professional.