Vital Interests (Processing Basis)

A legal basis for processing personal data under GDPR Article 6(1)(d) when necessary to protect someone's life or physical well-being, particularly in emergency situations where consent cannot be obtained. Vital interests provide lawful grounds for processing when: a data subject's life is at risk, processing is necessary to protect vital interests, and consent cannot be obtained (if consent can be obtained, it should be the legal basis instead). Examples include: sharing medical information in emergencies, processing health data during public health crises, disclosing location data to emergency responders, or processing data to prevent serious physical harm. The threshold is high—'vital interests' means life-or-death situations, not merely important interests or conveniences. This basis shouldn't be used routinely—if processing can be planned and consented to in advance, other legal bases are more appropriate. Organizations should: carefully document when relying on vital interests, use this basis only in genuine emergencies, process only information strictly necessary for protection, and consider whether consent or another basis might apply. Vital interests can also justify processing special category data under GDPR Article 9(2)(c) when protecting vital interests and the data subject is physically or legally incapable of giving consent.