Sensitive Personal Data
FADP classifies personal data as “sensitive personal data” if it relates to:
- religious, philosophical, political or trade union-related views or activities;
- health, the intimate sphere of the person or racial origin;
- genetic data;
- biometric data which unequivocally identifies a natural person;
- administrative or criminal proceedings and sanctions;
- social security measures.
Financial data is not sensitive personal data under the FADP. Switzerland's banking secrecy law, however, protects the confidentiality of the existence of the banking relationship, the identity of the bank's customer and any other information related to the banking relationship.
For sensitive personal data, more stringent requirements particularly apply to the consent of the data subjects to their processing (if consent is required, which is not generally the case). If extensive processing of particularly sensitive personal data is planned, there may be a high risk that leads to private controllers having to carry out a data protection impact assessment in advance.