Certain personal data is by its nature particularly sensitive and therefore it has stronger protection under the GDPR. This type of data, called special categories of data or sensitive personal data, is data that concerns racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, health, a person’s sex life or sexual orientation, genetic data and biometric data that uniquely identifies a person.
In general, processing of sensitive data is prohibited. There are however a number of exceptions; e.g. if the subject has consented to the processing of sensitive personal data. Do however note that there are specific requirements in relation to a valid consent under the GDPR.
In the cooperation between Klarna and the merchant, each party will process certain personal data. That processing is by each party done in the capacity of a data controller, being responsible for its own processing. However, the parties will also share certain personal data with each other.
If you are processing personal data which could be categorized as sensitive data, you have to make sure not to share that data with Klarna. As information regarding what goods the consumer has purchased normally is shared with Klarna, you have to make sure that names of goods are anonymized before that information is shared with Klarna.
Medical and pharmaceutical products may normally include goods which can reveal the health or sex life of a person. Therefore, you should never send any line item data regarding products that have a package leaflet which is regulated under the relevant implementation of the Directive 2001/83/EC of 6 November 2001 on the Community code relating to medicinal products for human use or similar local regulations. Such products may consist of, but are not limited to, antihistamines, paracetamol, ibuprofen, nasal spray, and other prescription and non-prescription-based medical products.
The same applies to herbal and natural wellness products with the same intent as medical and pharmaceutical products since they normally include goods which can reveal the health or sex life of a person.
Also, products such as condoms, ovulation, and pregnancy test may reveal information about the health or sex life of a person therefore you should not send line item data regarding such products either.
Instead of providing line item data for such products, you should blank out the name of the goods, or as a suggestion simply state that ‘pharmaceutical goods’ were purchased.
Adult products such as erotic movies, adult toys, and certain clothing and accessories may disclose information regarding a person's sex life or sexual orientation. Therefore, you should never send any line item data regarding products that can reveal such information. Instead, you should blank the information out or state ‘movie’, ‘product’, ‘clothing’, and ‘accessories’ whichever is applicable.
Goods such as books, clothing, and accessories can reveal political opinions, religious or philosophical beliefs, or trade union membership. This type of information is regarded as sensitive and therefore you should never send any line item data regarding such goods to Klarna. Instead, you should blank the information out or state ‘book’, ‘clothing’, ‘accessories’ or ‘product’ whichever is applicable.