The processing conditions are: The grounds for processing personal data under the GDPR broadly replicate those under the DPA. Data transfers to the UK could be affected by a recent ruling on state surveillance measures and the EDPB’s recently updated European Essential Guarantees following Schrems II. 2. GDPR personal data is a broad category. But there’s another type of personal data, called ‘special category’ data (sometimes called ‘sensitive’ personal data), in relation to which extra care must be taken. Document the entire process, update your privacy notice, including all relevant information regarding the processing of special category data. Identify what a lawful basis for personal data processing in your particular case is. Under the General Data Protection Regulation (GDPR), organisations must create a data retention policy to help them manage the way they handle personal information.. Definition under the GDPR: data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. If you process substantial amounts of genetic, biometric or health data, pay attention to national developments as Member States have a right to impose further conditions on the grounds set out in the GDPR. 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Make sure you are acquainted with all your obligations. 3. What constitutes a breach of personal data under the GDPR? If the data controller is processing sensitive personal data, at least one sensitive personal data processing condition must also be satisfied. Personal data is any information that can be used to identify a living person, including names, delivery details, IP addresses, or HR data such as payroll details. Processing special categories of data may entail other obligations, like appointing a DPO, conducting a DPIA, compliance with Article 22 regarding automated individual decision-making, including profiling, and the implementation of suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests. The term is used broadly and can include less specific information, such as IP address. On the condition that the processing relates only to the members, former members, or individuals who have regular contact with it regarding its purposes. If the processing is carried with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim. 9 GDPRProcessing of special categories of personal data. There are considerable differences between the processing of these two types of personal data. The following personal data are considered as special categories of personal data and are subject to specific processing conditions according to the Art. If you rely on consent, the consent mechanisms used should be reviewed to ensure they meet the higher threshold under the GDPR. • information gathered during the check-in or registration into a health facility or during the application for a medical treatment • patient medical history • information on any disability, illness, medical diagnosis, medical treatment, medical opinions • results of health tests, medical examination • fitness tracker data • appointment details • medical invoices from which you can find out details about individuals’ health, • chromosomal analysis • deoxyribonucleic acid (DNA) analysis • ribonucleic acid (RNA) analysis. The difference between personal data and sensitive personal data is that processing sensitive personal data requires additional protection granted by the GDPR, since processing those types of data can involve severe and unacceptable risks for fundamental human rights and freedoms. It will however become much harder to process information about criminal records. ICO issues Q&A on the UK's data protection landscape after the Brexit transition period, UK-US data sharing poses risk to UK’s GDPR adequacy decision application, CJEU issues verdict on EU-US Privacy Shield and Model Clauses. A common misconception about the GDPR is that all organisations need to seek consent to process personal data. The non-profit body has to make sure that the personal data is not disclosed outside that body without the proper consent of the data subjects. Sensitive personal data is a special category of data identified under Article 9 and Recital 51 in the GDPR. Examples of personal data include a person’s name, phone number, bank details and medical history. Personal data is any information relating to an identified or identifiable person. For processing to be lawful, you must be compliant with GDPR Article 6 -Lawfulness of processing. While remaining largely the same, there are some changes to the conditions for processing personal data and sensitive personal data. Under GDPR these are known as ‘special categories of personal data’ , and includes information about a person’s: 1. The processing is done in accordance with Article 89(1) and based on the law, which is proportionate to the goal that wants to be achieved, and with specific measures to safeguard the fundamental rights and the interests of the data subject. Non-personal data is data that does not need special protection. Check Article 9 of the GDPR and identify which of the 10 possible exceptions for processing sensitive personal data applies to your case. Some sensitive personal data can be logged by accident, like referral information from another website that provides sensitive services. The definition of personal data is modified and simplified, and the definition of sensitive personal data is retained and extended to cover genetic data and biometric data. In addition to complying with all six data protection principles (please see our briefing on GDPR: Data Protection Principles), when processing personal data a data controller must also satisfy at least one processing condition. It doesn't matter if it's something as obvious as a person's name, as seemingly innocuous as their IP address, or as sensitive as their medical records. Contact phone number must have at least 0 and no more than 24 characters. 5. Additional safeguards to protect sensitive data has to be provided. While the definition looks to have been simplified, the effect is to make it more detailed by reference to a series of identifiers including name, online identifiers (such as an IP address) and location data. The processing of the abovementioned types of data is prohibited by the GDPR. At the same time, the Member States can also introduce further conditions, including limitations, with regard to the processing of genetic data, biometric data, or data concerning health. The GDPR defines ‘personal data’ as any information relating to an identified or identifiable natural person (‘data subject’).” At first glance, this is a simpler definition when compared to the definition of personal data in the DPA 1998. Also, for you as a controller or processor, different sets of rules are applied when processing special categories of data. Or if it is necessary for carrying out the obligations related to employment, social security and social protection law. The GDPR also states that the Member States can add further specific conditions and limitations for genetic, biometric or health data. Whether in court proceedings or in an administrative or out-of-court procedure. There are certain principles, preconditions, and steps that need to be taken before processing any type of personal data, and this is applicable when processing a special category of personal data outlined in Article 5 of the GDPR: • personal data must be processed lawfully, fairly and transparently • data must be collected for a specific purpose • processing must be adequate, limited and relevant (data minimization principle) • data must be as accurate and kept up to date • data should be kept in a form which permits identification of data subjects for no longer than is necessary (storage limitation, anonymization, pseudonymization) • Implement adequate technical and organizational data protection measures. The processing conditions are: Processing is done for: • archiving purposes in the public interest, • scientific or historical research • statistical purposes. Definition under the Data Protection Act 1998 (DPA): data which relate to a living individual who can be identified: (b) from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller; and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual. However, the processing should be permitted by law, and proportionate to the goal that is pursued. Some of the personal data that companies process is more sensitive and needs higher protection. Article 9 of the GDPR, explains that the processing of sensitive personal data is prohibited, with certain exemptions. We will go over what “personal data” is according to the GDPR. It also redefines the very meaning of ‘personal data’ compared with the present legislation, so that is worth exploring as well. In all cases, adequate safeguards for the protection of fundamental rights and interests of the data subject have to be present. GDPR establishes the prohibition of processing of these categories of sensitive data with specific exceptions: In case the party concerned has given his or her explicit consent. Our data protection lawyers deliver straightforward, commercial advice to help our clients ensure compliance with data protection regulation. Of course, there are certain exemptions that we will discuss later on. Check with your supervisory authority to find out if there are any additional limitations regarding the processing of genetic data, biometric data or data concerning health. GDPR Article 10 will give you more information on this. Getting consent. The GDPR makes a distinction between regular personal data and sensitive personal data. In order to lawfully process special category data, you must identify both a lawful basis under Article 6 of the GDPR and a separate condition for processing under Article 9. The processing of special category data, can affect your other obligations in particular the need for documentation, DPIA, DPO and EU representatives. If you can not find an appropriate exception for your case, then you will not be able to process sensitive data. The following personal data is considered ‘sensitive’ and is subject to specific processing conditions: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; trade-union membership; genetic data, biometric data processed solely to identify a human being; health-related data; There’s no definitive list of what is or isn’t personal data, so it all comes down to correctly interpreting the GDPR’s definition: The inclusion of genetic and biometric data is new. Personal data is governed by the data protection principles of the GDPR. (h) any proceedings for any offence committed or alleged to have been committed by him, the disposal of such proceedings or the sentence of any court in such proceedings. Definition under the DPA: personal data consisting of information as to: (a) the racial or ethnic origin of the data subject; (c) his religious beliefs or other beliefs of a similar nature; (d) whether he is a member of a trade union; (e) his physical or mental health or condition; (g) the commission or alleged commission by him of any offence; or. Special category data is the sort of personal data that you must treat extracarefully. Under the GDPR, personal data is data that relates to or can identify a living person, either by itself or together with other available information. 12 11 Art. If you keep sensitive data for too long – even if it’s being held securely and not being misused – you may still be violating the Regulation’s requirements. In fact, consent is only one of six lawful grounds for processing personal data, and the strict rules regarding lawful consent requests mean it’s generally the least preferable option.. Recital 53 deals with the processing of sensitive data in the healthcare and social sector. When going through the list of what is considered to be sensitive personal data, there are new terms being introduced and therefore need further clarification: • facial recognition • fingerprints • voice recognition • iris scanning • palmprint verification • retina recognition. Message must have at least 0 and no more than 1024 characters. Definition under the GDPR: any information relating to an identified or identifiable natural person. However, if you identified the proper exception, there are few of them that require further support in EU law or Member State law. hbspt.cta.load(5699763, '92bc290a-539a-4e07-864c-c1ca928a0ae6', {}); Try Data Privacy Manager and experience how you can simplify managing records of processing activities, third-parties, or data subject requests! The first fine issued by the ICO (if we exclude Marriot and British Airlines which are not finalized), was issued to a Pharmaceutical Company (€320,000 or £275,000). There are certain exceptions to the prohibition of the processing of special category data. Where it is allowed by Union or Member State law and performed under special safeguards to protect personal data and other fundamental rights: • in the field of employment law, • social protection law (including pensions) • health security reasons, • protection of vital interest of data subject • public health and the management of health-care services • in the context of a legal claim • archiving, research, and statistics (if permissible by law) • public interest, Further elaborated in Recital 52: “Derogating from the prohibition on processing special categories of personal data should also be allowed when provided for in Union or Member State law and subject to suitable safeguards, so as to protect personal data and other fundamental rights, where it is in the public interest to do so, in particular processing personal data in the field of employment law, social protection law including pensions and for health security, monitoring, and alert purposes, the prevention or control of communicable diseases and other serious threats to health.”. Processing should also be conducted with respect to the right to data protection and provide safeguard measures to the fundamental rights and the interests of the data subject; Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of: • the working capacity of the employee, • medical diagnosis, • the provision of health and social care • provision of health treatment • management of health • management of social care systems and services. As we said in GDPR after Brexit, consent is the pivotal issue with regards to data … The GDPR distinctly specifies which data is considered sensitive and fall under the special category of data: • data related to racial or ethnic origin, • political opinions, • religious or philosophical beliefs, • trade union membership, • genetic data, • biometric data for the purpose of uniquely identifying a natural person, • data concerning health, • data concerning an individual’s sex life or sexual orientation. CJEU ruling on Privacy International case; could it frustrate UK’s GDPR Adequacy Decision? Be aware of what can be included under ‘identifiable natural person’ as part of the definition of Personal Data. 7. If the data controller is processing sensitive personal data, at least one sensitive personal data processing condition must also be satisfied. Personal data can seem abstract and trivial, but a lot of it can be very sensitive and even dangerous if left unsecured. You must only collect personal data if you need it, you must store it securely, and you must not share it carelessly. Categories of (sensitive) Personal Data under the GDPR The entire General Data Protection Regulation (GDPR) revolves around the protection of personal data, how personal data can be used and so forth. The next step will be assessing if you need to complete a data protection impact assessment (DPIA) for any type of processing which is likely to be high risk. 9 of the GDPR: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; trade-union membership; GDPR Requirements 4. This processing has to be permitted by Union or Member State law or pursuant to contract with a health professional. There are certain types of data that the General Data Protection Regulation (GDPR) considers to be sensitive personal data and therefore classifies them under the special category of personal data. Personal data covers a much broader definition than the previous legislation demanded. This kind of processing is aimed at cross-border threats to health and ensuring high standards of safety of health care, medicinal products or medical devices. Make sure your processing is done according to the principles and requirements outlined in Article 5. Personal data. The GDPR requires that you treat all personal data with care. Personal data. This data requires a higher degree of protection due to the nature of the information and because the processing of the information could create “significant risks to the fundamental rights and freedoms” of the data … The processing of personal data will only be lawful if it satisfies at least one of the following conditions: The grounds for processing sensitive data under the GDPR broadly replicate those under the DPA, but have become slightly narrower. The value of the Contact phone number field is not valid. Data processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity. Review the conditions on which your organisation processes personal data and sensitive personal data. What is sensitive data under the GDPR? Under the GDPR, ‘personal data’ means “any information relating to an identified or identifiable natural person”. An individual can give explicit consent for one or more specified purposes, except where the European Union or Member State decides that the prohibition can not be lifted by the data subject. This means that personal data allows identification of a data subject directly or indirectly, by name, an identification number, location data, an online identifier or physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Take this into consideration if processing data related to: employment, social security, and social protection; sensitive data in the public interest; data regarding health, social care or public health; and archiving research, and statistics. If the processing of sensitive data is authorized by law, and necessary for exercising the data controller or data subject’s rights. Personal data means any information related to an individual that can be used to identify them directly or indirectly. The special categories specifically include: genetic data relating to the inherited or acquired genetic characteristics which give unique information about a person’s physiology or the health of that natural person Personal data is at the heart of the General Data Protection Regulation (GDPR).However, many people are still unsure exactly what ‘personal data’ refers to. In addition to complying with all six data protection principles (please see our briefing on GDPR: Data Protection Principles), when processing personal data a data controller must also satisfy at least one processing condition. Prohibition to process sensitive data. Sensitive data may be processed, if it is crucial to protect the vital interests of the data subject or of another individual, and the data subject is physically or legally incapable of giving consent. 8. The processing of sensitive data is aimed at the prevention or control of contagious diseases and other health threats. Review existing data collected and processed and identify whether your organisation collects and processes data caught by the expanded definitions under the GDPR. The fine was issued on the fact that the pharmacy had insufficient technical and organizational measures to ensure the security of a special category of data. As specified in Article 9 you can still process sensitive personal information if: Processing of sensitive personal data is possible if the data subject has given explicit consent to the processing of those data. It is permissible to process sensitive personal data of a data subject if the data subject has already made the data public and accessible. When processing sensitive personal data, the first thing is making sure that there no other way to achieve the desired goal that would be less intrusive on personal data of the individual. While it includes the obvious personal information such as This includes credit card number, email address, name and date of birth, it … There are two main types of data under the GDPR: personal data and special category personal data. The data can be non-personal, personal or sensitive. hbspt.cta.load(5699763, '8bbe6113-4223-4f7d-9411-9829ac8a5127', {}); Not every piece of information is considered to be personal data, and the GDPR offers a definition of what qualifies as personal data. The DPA 2018 also mirrors the GDPR's focus on "demonstrating accountability" by requiring employers to retain any such policy document for at least 6 months following the end of any processing activity involving sensitive personal data, during which period it must be periodically reviewed, updated and provided without charge to the ICO upon request. These do not have to be linked. Identify whether your organisations' conditions for processing have an effect on individuals' rights. We will be covering individuals' rights later in this series. Before you process sensitive personal data you must fully understand what lawful grounds you have for the processing. The processing of sensitive data is allowed if there is a considerable public interest at stake. Name must have at least 0 and no more than 256 characters. Processing in the name of public health has to be based on the EU or Member State law with appropriate measures and safeguards to protect the rights and freedoms of the data subject, in particular, professional secrecy. hbspt.cta.load(5699763, '40b50953-1c20-4175-ae10-501f3ed52483', {}); Several GDPR breaches occurred during the admittance of the patient that resulted in issuing the wrong invoice to the patient and revealed more serious privacy issues the hospital was struggling with. Processing of sensitive personal data is as a rule prohibited but there are certain exceptions. [Video & Infographics], Best Online Privacy Practices for Small Business, Discover how Master Data Management can help you comply with GDPR, First GDPR fine in Croatia issued to an unknown Bank. This is a modified concept. The definition previously included information about criminal convictions – this is now treated separately and subject to even tighter controls. Personal data may also include special categories of personal data or criminal conviction and offences data. Sensitive personal data is also covered in GDPR as special categories of personal data. hbspt.cta.load(5699763, 'd338d6fd-76ae-48c8-8175-86371aa3e9aa', {}); 6. Personal data is information that relates to an identified or identifiable natural person. Types of data. Any processing of personal data must satisfy at least one of the following conditions: Although the definitions are broader than the equivalent definitions in the current DPA, for the most part they are simply codifying current guidance and case law on the meaning of 'personal data'. The difference between personal data and sensitive personal data is that processing sensitive personal data requires additional protection granted by the GDPR, since processing those types of data can involve severe and unacceptable risks for fundamental human rights and freedoms. Additionally, according to the Recital 51, photographs are considered biometric data only when they are processed with a specific means that allow the unique identification of a data subject, despite the fact that photography can reveal someone’s racial identity or other sensitive information. Special category data is personal data that needs more protection because it is sensitive. If you want to make sure everything is compliant, contact your supervisory authority and make sure you get acquainted with the regulation and law governing the area of your interest to meet additional conditions. Conducting a DPIA is an important aspect of the General Data Protection Regulation (GDPR) accountability obligations of an organization. In court proceedings or in an administrative or out-of-court procedure between regular data! 10 will give you more information on this to seek consent to process about., but a lot of it can be included under ‘ identifiable natural person ’ as part of the data... It will however become much harder to process personal data gdpr sensitive personal data prohibited by GDPR! That does not need special protection states can add further specific conditions and limitations genetic... That we will discuss later on definition than the previous legislation demanded done:! For: • archiving purposes in the healthcare and social protection law and... 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