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CASRAI

Definition · Plain-language

Sensitive data (special category data)

Sensitive data — known as special category data under GDPR — is information that needs extra protection because of the heightened risk its misuse poses to individuals.

CASRAI research-methods explainer — Sensitive data (special category data)

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What counts as sensitive data

Under GDPR Article 9, special category data covers personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, together with genetic data, biometric data used to identify a person, data concerning health, and data about a person’s sex life or sexual orientation. These categories are singled out because their disclosure can expose people to discrimination or serious harm. Information about criminal convictions is handled under a separate, related provision rather than Article 9 itself.

Why it gets extra protection

Processing special category data is treated more cautiously because the consequences of a breach or misuse are more severe. Beyond having a normal lawful basis, organisations generally need an additional condition specifically permitting the sensitive processing. In a research context this often shapes consent design, security controls and access arrangements. The underlying principle is proportionality: the more sensitive the data, the stronger the safeguards expected around it.

Sensitive data in research practice

Many research domains — clinical, social and biomedical — inherently involve sensitive data. Recognising data as sensitive informs classification, storage and sharing decisions, and often determines whether a privacy or data-protection impact assessment is appropriate. Robust de-identification and anonymisation become especially important here, since the goal is to enable valuable reuse of data while keeping the heightened risk to participants firmly under control.

Key facts

At a glance

  • Definition: personal data needing extra protection due to heightened risk
  • GDPR term: special category data (Article 9)
  • Categories: health, genetics, biometrics, race, religion, beliefs, sex life
  • Politics: political opinions and trade-union membership included
  • Separate rule: criminal-offence data handled outside Article 9
  • Effect: generally needs an extra processing condition plus safeguards

Common misconceptions

What people often get wrong

Often heard: Any personal data a person considers private counts as sensitive data.

Actually: Special category data is a defined GDPR list — health, genetics, biometrics, race, beliefs, sex life and similar. Other private-feeling data is still personal data but not legally “special category”.

Often heard: Criminal conviction data is special category data under Article 9.

Actually: Criminal-offence data is handled under a separate, related provision rather than Article 9, although it still attracts heightened protection.

Often heard: A photograph is automatically biometric special category data.

Actually: A photograph becomes biometric special category data only when processed through specific technical means to uniquely identify a person; an ordinary image alone is generally not special category data.

Referenced across the research world

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  • Harvard University logo
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  • Stanford School of Medicine logo
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