Key Definitions
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Personal data

Last review date: January 2025

"Personal data" means any information relating to an identified or identifiable natural person. An "identifiable person" is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Sensitive/special personal data (including personal data subject to additional protections/ restrictions/breach notification obligations)

Last review date: January 2025

Sensitive data includes:

   personal data revealing racial or ethnic origin
   personal data revealing political opinions
   personal data revealing religious or philosophical belief
   personal data revealing trade / professional union or association membership
   genetic data
   biometric data for the purpose of uniquely identifying a natural person or biometric templates
   data concerning health/medical information
   data concerning a natural person's sex life or sexual orientation
   government identity card or number information
   personal data regarding an individual's criminal convictions or record
   other

For some Member States a broader scope of sensitive/special personal data may apply.

Controller vs Processor

Last review date: January 2025

Do the privacy laws distinguish between controllers/owners and processors/agents? Whereby:

  • the controller/owner is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data
  • the processor/agent is natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller

Yes