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GlossaryLegal

Special Categories of Data

Data considered sensitive by GDPR (art. 9) receiving reinforced protection: health, biometrics, ideology, orientation, religion, racial origin.

Definition

GDPR (art. 9) singles out a set of especially sensitive data receiving reinforced protection: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data when used to uniquely identify a person, health data and data concerning sex life or sexual orientation.

Processing is prohibited by default. Only allowed if one of the art. 9.2 exceptions applies: explicit consent, legal obligation, vital interests, preventive medicine, public health, archiving, research or statistics. In a sports-club context, almost all processing in these categories relies on explicit consent (health-related image, medical form) or legal obligation (LOPIVI).

When does it apply?

Applies in every club handling medical forms (allergies, conditions, injuries, physical-effort authorisation), cardiovascular fitness tests, disability data for sport adaptation, biometrics (fingerprints for facility access, if any) or, indirectly, image of minors when tied to a health context (rehab video, for example).

Practical example

C.D. Triatlón Norte collects in its member form: name and identifiers (ordinary categories), blood type and allergies (special — health) and an over-50 physical-activity medical clearance (special — health). For the special categories it requires explicit consent signed separately, keeps data only during membership and destroys or returns them on exit. Medical-form access is restricted to coaches and team delegates; the rest of the board does not consult it.

Related terms

Go deeper

Long-form guides and product pages where we cover this topic in depth:

This is not specific legal or tax advice

Information as of May 2026. Regulation evolves and every club has its own casuistry (region, federation, size, activities). For your specific case talk to a lawyer or tax advisor specialised in Spanish sports law.

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