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Handling Sensitive Categories of Data Print

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Information needing extra care.

WHAT IS TYPICALLY TREATED AS SENSITIVE

Health information Racial or ethnic origin Religious or philosophical beliefs Political opinions Trade union membership Genetic and biometric data Sex life and sexual orientation

WHY THEY ARE SEPARATE

Misuse causes disproportionate harm, including discrimination.

WHAT PROCESSING THEM USUALLY REQUIRES

A lawful basis, plus an additional condition.

WHAT ADDITIONAL CONDITIONS TYPICALLY INCLUDE

Explicit consent Employment or social protection obligations Vital interests Legal claims Substantial public interest, as defined

WHAT TO DO FIRST

Ask whether you need it at all.

WHY

Most organisations collect sensitive data without a genuine need.

WHAT EXAMPLES LOOK LIKE

Health questions on forms with no purpose Religion collected for no stated reason

WHAT TO DO ABOUT THOSE

Stop collecting them.

WHAT EXTRA MEASURES TO APPLY WHERE YOU DO

Restricted access Encryption Shorter retention Additional logging

WHAT TO BE CAREFUL WITH

Data revealing sensitive categories indirectly.

WHAT EXAMPLES LOOK LIKE

Dietary requirements implying religion Photographs implying ethnicity Purchase history implying health

WHAT TO DOCUMENT

The condition relied upon, per activity.

WHAT TO TAKE ADVICE ON

Anything involving health or biometric data at scale.


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