Sensitive Data — ResGuard

Key Concept 2 — Sensitive Data

Some data can cause serious harm if misused — the law protects it more strictly.

Sensitive data (also called special categories of personal data) can lead to discrimination, exclusion or other serious harm. The categories differ between laws, so always check your local list.

What is typically sensitive

Health data, including sick notes, disabilities and vaccination status
Racial or ethnic origin, religious and political beliefs
Trade union membership, sexual life and orientation
Genetic and biometric data, e.g. fingerprints for time recording
Often treated with similar care: criminal records, financial data, national ID numbers and data about children

What this means in practice: stricter conditions such as explicit or written consent, stronger security, access only for those who need it, and in many laws a risk assessment before you start.

Sensitive data in your jurisdiction

Singapore

National identification numbers such as NRIC
Financial data, e.g. bank account details
Health and medical data
Data about minors
Biometric data

The PDPA has no statutory list of special categories, but the PDPC expects a higher standard of protection for sensitive data, and penalties are higher when such data are affected. From 31 December 2026, NRIC numbers must not be used for authentication.