Article 9 (i) doesn’t seem relevant to this scenario. Recital 54 also precludes processing health data for reasons of public interest by employers so I think you would struggle to rely on this. 9(h) is also subject to the conditions in Article 9(3) which I don’t think would apply to first aiders; I read it as being reserved for medical practitioners like nurses and doctors.
Claire Miller
Information Governance Manager & Data Protection Officer Legal and Governance University of Central Lancashire
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-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Emile Douilhet
Sent: 11 June 2019 15:07
To: [log in to unmask]
Subject: Re: [data-protection] lawful basis for first aiders
Would it not be possible to use 9(i) on "preventive or occupational medicine"? That is generally the one I recommend for healthcare-related concerns. 9(h) is possible in the public sector, so depends on the context, but 9(i) has been quite useful for me so far.
Emile
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