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We process health or religion data, is that simply allowed?

Special categories under GDPR Article 9 are only processable under a specific exception: explicit consent, an employment-law duty, or healthcare provision, for example.

Try this first

  1. 1Find where special categories appear: sick-leave, catering allergies, union membership, biometrics for access, diversity-survey responses.
  2. 2Pick the right Article 9(2) exception per processing. Sick-leave usually rides on the employment-law exception, with the company doctor as processor.
  3. 3Limit who can see it. Sick-leave does not belong with all of HR, only with strictly needed roles.
  4. 4Document extras: stronger security, shorter retention where possible, and a DPIA if processing is large-scale or structural.
  5. 5Train the people involved in what they may and may not record. The cause of a sick-leave call, for example, often cannot be logged by HR.

When to bring us in

Large-scale processing of health, biometric or criminal data is not optional ground for a DPIA and legal review.

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