vital interests policy
Date Reviewed: 16th march 2026
Effective Date: 2nd november 2023
Next Review Due: 16th march 2027
1: introduction
This policy outlines the circumstances under which I may process personal data using the vital interests lawful basis under the UK GDPR. This basis is used only in exceptional and urgent situations where processing is necessary to protect someone’s life and the individual is unable to give consent.
2: Lawful Basis for Processing
Under the UK General Data Protection Regulation (UK GDPR), the lawful basis for processing personal data under vital interests applies in critical situations where it is necessary to protect the life of an individual. Unlike previous regulations, this basis now extends to protecting the vital interests of any person, not just the data subject.
3: Scope of Vital Interest Processing
- This lawful basis applies in critical situations where processing personal data is necessary to protect the life of the individual or another person.
- Not for Planned or Routine Processing: It is not appropriate for planned medical care or processing on a large scale. This basis is not intended for routine data processing activities.
4: Special Categories of Data
When processing special category data (such as health information) under this basis, I ensure to identify and apply an additional condition for processing as specified in Article 9 of the UK GDPR.
When processing special category data such as health information under this basis, I rely on the Article 9 condition that processing is necessary to protect the vital interests of the data subject or another person where the individual is physically or legally incapable of giving consent.
5: Documentation and Justification
- Circumstances: I document specific circumstances where processing under the vital interests basis is relevant. This typically involves situations where immediate action is necessary to protect an individual’s life, and obtaining consent is not possible.
- Justification: I clearly document my justification for relying on this basis, ensuring that the processing is strictly limited to what is necessary to protect vital interests.
- Informing Individuals: I inform individuals about my reliance on this basis where necessary and appropriate, ensuring transparency in my data processing activities.
6: Guidance
- Guidance: I provide clear guidelines for recognizing and applying the vital interests basis. This includes understanding the circumstances that justify its use and ensuring that data processing is limited to urgent and life-threatening situations.
- Training: keep my knowledge up to date through continuing professional development and by reviewing guidance from relevant professional and regulatory bodies.
7: review and documentation
- Ongoing Processing: I regularly review my processing activities to identify if any ongoing processing relies on the vital interests basis or if future processing may require it.
- Documentation: I maintain detailed records of where and why I rely on the vital interests basis, ensuring that all such processing is well-documented and justified.
- This may include situations involving medical emergencies or serious safeguarding concerns where sharing information is necessary to protect life.
8: policy review
This policy is reviewed annually or as needed to reflect changes in legislation, operational practices, or relevant guidance. Updates are communicated as necessary.
9: contact information
For any queries regarding this policy or to request further information, please contact me at:
Jamie Louise Hollis
Email: adhdslt@outlook.com
Website: www.adhdslt.co.uk
Signed: Jamie Louise Hollis, ADHD SLT
Job Title: Speech and Language Therapist