Sensitive data: the definition is in article 5 FADP
Updated on October 24, 2026
Article 5 FADP treats as sensitive personal data those on religious, philosophical, political or trade-union opinions or activities, on health, the intimate sphere or racial or ethnic origin, on social-assistance measures, on administrative or criminal proceedings or sanctions, and genetic and biometric data identifying a person. Not every important datum is sensitive. A client number is not sensitive by itself. The statutory list is on Fedlex.
The relevant article
An employee's health in a medical certificate sent to human resources is sensitive data. Access stays limited to the people who need it for the employment relationship.