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Article 9 GDPR (Special Category Personal Data)
With regards to Article 9 and Special Categories , my question is - Do I obtain consent from the Data Subject to process their Special Category data when they voluntarily submit their Special Category data into a chatbot/social media platform etc or would the Chatbot have to explicitly provide for an Opt-In form of consent BEFORE any data is entered into the chatbot?
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EU GDPR DOCUMENTATION TOOLKIT
Step-by-step implementation for smaller companies.
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EU GDPR DOCUMENTATION TOOLKIT
Step-by-step implementation for smaller companies.
Find out more
EU GDPR DOCUMENTATION TOOLKIT
Step-by-step implementation for smaller companies.
Find out more
Expert
Andrei Hanganu
Dec 10, 2018
Answer:
What you should do is clearly mention in your Terms & Conditions that your users should not introduce any special categories data in the chatbot/social media platform and if they do so they are the only one who is responsible for any damages.
Don’t think there is something more you can do as you can't ask for the consent of processing special category data as you don't actually need to process it.
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Dec 10, 2018
Dec 10, 2018
Dec 10, 2018