Data Protection Policy

Appendix A – Further Guidance on Conditions for Processing

Employment, Social Security and Social Protection

This condition is met if:

  • The processing is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection, and
  • When the processing is carried out, the controller has an appropriate policy document in place.

Health and Social Care Purposes

This condition is met if the processing is necessary for one of the following purposes:

  • Preventative or occupational medicine
  • The assessment of the working capacity of an employee
  • Medical diagnosis
  • The provision of health care or treatment
  • The provision of social care, or
  • The management of health care systems or service or social care systems or services.

Personal data may be processed for these purposes when processed by or under the responsibility of a professional subject to the obligation of professional secrecy established by national competent bodies.

Public Health

The condition is met if the processing:

  • Is necessary for reasons of public interest in the area of public health, and
  • Is carried out –
    • By or under the responsibility of a health professional, or
    • By another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law.

Research, etc

This condition is met if the processing:

  • Is necessary for archiving purposes, scientific or historical research purposes or statistical purposes
  • Is subject to appropriate technical and organisational safeguards including, e.g. data minimisation, pseudonymisation.  Where the purpose can be met without the identification of the data subject, those purposes should be fulfilled in that manner.
  • Such processing does not satisfy requirements if the processing is likely to cause substantial damage or distress to a data subject or if the processing is carried out for the purposes of measures or decisions with respect to a particular individual.


ID: 9853, revised 06/04/2023