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GlossaryLegal

Explicit Consent

Unambiguous and specific declaration by a data subject authorising the processing of their data, required by GDPR for special categories (image, health) and high-impact decisions.

Definition

Explicit consent is one of GDPR's legal bases (art. 9.2.a). Unlike ordinary consent (which can be expressed by clear affirmative action), explicit consent requires an unambiguous and specific declaration: an actively and separately ticked box, an electronic or handwritten signature, an email with express affirmation. Required when processing special categories of data: health, biometrics, orientation, religion, ideology, racial origin.

It must be freely given (not conditioned to another service unless necessary), specific (separate for each purpose), informed (with art. 13 information) and revocable at any time without detriment. The burden of proof that consent was properly obtained lies with the controller.

When does it apply?

Applies in every sports club for: image of minors on social media and website, health data (medical forms, injuries, allergies), data on minors in general (with parental consent), marketing communications (newsletter unrelated to the activity), data sharing with third parties not mandated by contract or law. Doesn't apply to processing based on contract (membership fee) or legal obligation (sharing with federation).

Practical example

When enrolling a minor at C.D. Patinaje Hielo, parents sign three separate documents: 1) the membership contract (contractual basis, no explicit consent needed), 2) the medical form with allergies and conditions (basis: explicit consent for health data), 3) the social-media image consent (explicit and revocable; separate box with 'yes, I authorise' or 'no, I don't'). All three are stored digitally signed and revocable by parents at any time.

Common mistakes

  • Using a single checkbox for everything: violates specificity. Each purpose needs its own consent.
  • Conditioning enrolment on image consent: consent isn't free if conditional on the service.
  • Forgetting revocation: the club must have a simple procedure (an email is fine) to withdraw consent.
  • Pre-ticked boxes: consent must be an affirmative action, not inaction.

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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