What Personal Data is covered by the GDPR?

Personal data is anything that can directly or indirectly be used to identify an individual and includes:

  • Name
  • ID number
  • Location data
  • An online identifier
  • Sensitive personal data


Sensitive personal data is referred to as “special categories of personal data” in the GDPR and includes genetic and biometric data.  It no longer includes personal data relating to criminal convictions as this is now covered in its own section (Article 10).

Special categories of Personal Data include:

  • race
  • ethnic origin
  • politics
  • religion
  • trade union membership
  • genetics
  • biometrics (where used for ID purposes)
  • health
  • sex life
  • sexual orientation

Trade Union membership is particularly relevant in our industry since we often collect this for Pension purposes on contracts.  Therefore it is important to understand the additional steps required for processing this data.