GDPR: who are considered to be vulnerable persons?

Sometimes mention is made of vulnerable natural persons in the context of the General Data Protection Regulation (GDPR).


  • minors
  • pregnant women
  • the elderly
  • people with mental disorders
  • asylum seekers
  • people with disabilities
  • ethnic minorities
  • the sick and patients

These are often persons who are legally incompetent, persons who cannot give their consent, or persons who may suffer very adverse consequences if their personal data were to become publicly available (see also European Commission, (2021) “Ethics in Social Science and Humanities” Guidelines, page 11).

If you want to include vulnerable people in your research, you need to justify it. The question you need to answer here is: can the research results be obtained by including another, less vulnerable group in your research?

Fulfilment of the criterion of vulnerable person is highly dependent on the context of your research. For example, a research project that incorporates political preferences will entail a much higher risk if this occurs in repressive regimes.

Implications for data processing

The processing of personal data of vulnerable persons can give rise to a DataProtection Impact Analysis (a risk analysis, included in the GDPR register).

In addition, this will also affect how you must provide information to the data subjects and ask for consent from the data subjects.

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Last modified March 12, 2024, 2:26 p.m.