Special Categories of Personal Data

Personal data defined in GDPR Article 9 as revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for unique identification, health data, or data concerning sex life or sexual orientation. These categories receive enhanced protection due to inherent sensitivity and discrimination risks. Processing is generally prohibited unless specific conditions are met: explicit consent, employment/social security/social protection law (where authorized), vital interests (when data subject cannot consent), legitimate activities of foundations/associations/non-profits, data manifestly made public by the data subject, legal claims, substantial public interest, healthcare purposes, public health, or archiving/research/statistics with safeguards. Even when exceptions apply, organizations must implement additional safeguards including Data Protection Impact Assessments, enhanced security measures, access restrictions, staff training, and careful documentation of necessity and proportionality. Organizations should minimize collection of special category data, carefully evaluate legal bases, implement technical and organizational protections, and maintain detailed records justifying processing.