We're in the process of adding the records of or volunteers onto an electronic database.
There are two things we feel we should know, firstly if a volunteer has some form of medical condition that it might be useful to know about in an emergency situation - e.g. someone has a particular allergy, or a heart condition or something and knowing about it could potentially save their life. Secondly if they have a condition that would affect their ability to undertake a function that was intrinsic to their role.
This is out of my area of knowledge, but obviously it's sensitive personal data, so *I'm trying to work out the appropriate basis for processing*.
My issue is that we almost qualify on a few counts, but I'm not sure any are actually robust enough. i.e.
9.2.a - We ask them to fill the info onto a paper form (which they can leave blank) but I'm not sure that is not sufficiently clear to count as informed consent(?)
9.2.b/9.2.h - "obligations under employment, social security or social protection law" they are volunteers rather than paid, but does that make a difference?
9.2.c - It would be used to protect their vital interests, and at the time we were to use it they would be physically or legally incapable, but obviously that wouldn't be the case when they complete the form.
We're also a not-for-profit (9.2.d) but that's obviously not relevant here.
Any pointers?
Matt
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