Conditions for processing special category data

Under the General Data Protection Regulations (GDPR), special category data is more sensitive than other data and so needs more protection. In order to lawfully process special category data, we must have both a lawful basis for processing the data under Article 6 of the GDPR, as well as a special category condition under Article 9 of the GDPR.


We only process special category data which concerns health, as we must store zero-rated VAT eligibility forms, which may contain data concerning health, with our tax records.

We rely on the condition outlined in Article 9(2)(a) in order to process special category data, which states, “the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject”.


This means that we can only process this type of data with your explicit consent, which we will obtain via a paper form. Please be aware that if you are unwilling to give us your consent to process special category data, then we may be unable to charge you at zero-rated VAT.