Special Category Data Needs Extra Friction
Recognize when sensitive personal data requires stronger justification and minimization.
Sensitivity changes the burden of proof. A normal field-review habit is useful; a sensitive-data review requires more skepticism and clearer controls. Spot the sensitivity Health, biometric, union, racial or ethnic origin, political opinion, religious belief, sex life, sexual orientation, and similar categories are not just more fields. They can create discrimination or dignity harms if mishandled. Reduce identifiability Ask whether aggregate reporting, pseudonymous IDs, or threshold rules can meet the purpose. If names are not needed, remove them before transfer. Watch consent in power-imbalanced settings In employment or service-dependent contexts, consent can be fragile. A person may feel they cannot…
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