Special category data: the Article 9 list and its exam traps
Data revealing race, politics, religion, union membership, genetics, biometrics for ID, health, sex life, or sexual orientation. The exam trap is assuming any sensitive data is special category — only the Article 9 list counts.
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Special category data under GDPR Article 9 is a closed list of ten types: race or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data used for identification, health, sex life, and sexual orientation. The key is that not all sensitive information qualifies — for example, a person's salary or criminal record is sensitive but not special category. Only these ten items trigger the general prohibition on processing, unless you find a specific exception in Article 9(2).
To avoid confusion, remember the mnemonic 'PRRUBBGHSS' — Politics, Race, Religion, Union, Biometrics, Genetics, Health, Sex life, Sexual orientation. A common exam trick is to present a scenario with 'sensitive' data like financial details or a photo of someone's face; the photo is not special category unless it is biometric data used for identification. Another trap is assuming that all health data is special category — it is, but only if it reveals a person's physical or mental health status, not just a generic sick note.
Test yourself: if a question lists 'criminal convictions' or 'salary', cross it out — it is not special category. For a quick recall, think of the ten items as the ones that could be used to discriminate against someone in a job or social setting. If you can tie each item to a real-world example, like a trade-union membership card or a genetic test result, you will lock the list in memory without needing a separate checklist.
Which data categories get special GDPR protection?
Data revealing race, politics, religion, union membership, genetics, biometrics for ID, health, sex life, or sexual orientation.