TLDR:
Sensitive data refers to special categories of personal information that require enhanced protection under privacy laws, including health, financial, biometric, and racial/ethnic data.
Categories of Sensitive Data
Under GDPR Article 9, sensitive data includes: racial/ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for identification, health data, sex life and sexual orientation. Other laws add categories like financial information (GLBA), children’s data (COPPA), and government-issued IDs. Each category carries specific compliance obligations.
Legal Bases for Processing
Processing sensitive data generally requires explicit consent or another specific legal basis like vital interests, public interest, or healthcare necessity. Even with consent, organizations must implement enhanced security measures, conduct impact assessments, and maintain detailed records. Cross-border transfers of sensitive data face heightened scrutiny and may require specific safeguards.
Practical Implementation
Startups handling sensitive data should implement data classification systems, encryption at rest and in transit, strict access controls, audit logging, regular security assessments, and clear data retention policies. The cost of a sensitive data breach is significantly higher than ordinary data — both in regulatory fines and reputational damage.
Sensitive Data Categories
Under GDPR Article 9, sensitive data (“special category data”) includes: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identification purposes, health data, and data concerning sex life or sexual orientation. Each category requires specific legal basis beyond ordinary processing — typically explicit consent, vital interests, or specific statutory authorization. Turkish KVKK Article 6 provides similar categorization with comparable protections. Children’s data is treated as inherently sensitive under most regimes, requiring parental consent for processing of children under defined ages (16 under GDPR, varying under KVKK).