Special Category Data Needs an Extra Gate
Use a practical path to test whether planned collection of special category data has a justified purpose, fitting condition, and safeguards.
Survey redesign A wellbeing survey asks employees for diagnoses, medication changes, disability accommodations, and manager support ratings. The team may be trying to help, but special category data needs more than good intentions. Article 9 Necessity first, then the extra legal gate Special category data needs an Article 6 basis, an Article 9 condition, and stronger safeguards. Missing any one of those weakens the whole design. It is voluntary, so it must be fine Voluntary does not automatically make the collection necessary or the consent valid. A smaller, more defensible use of sensitive data or a decision not to collect…
Sign up free — one personalized lesson every day, matched to your role and goals.
Already have an account? Sign in