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Collecting inferred data

Inferring such characteristics, for example using visual appearance, is a very high-risk approach to data collection, not only producing lower quality data but also has the risk of inferring incorrectly participant’s characteristics.

Inclusive data is generally special category data and is covered by data protection legislation (see section 5) and if collected inappropriately can result in legal risks too.

It does not matter whether the inferences are correct, but whether inferences are being linked to one of the special categories to influence the way research and/or data collection activities are being undertaken and how the data will be treated.

Recruiters need to ensure they are not processing inaccurate, inadequate or irrelevant personal data (in line with the accuracy data protection principle), and that for example, any inferences which are made are directly relevant and necessary for the purpose i.e., the research purpose, and that this is in line with the data minimisation data protection principle (see Section 5 for more details about the data protection requirements).

For more detail see:

GDPR in Brief No.10: Collection of Ethnic Data and Other Special Category Data