DAT-050 · Collect dietary and health information (Art. 9 GDPR)

Travel & housing · master data

Status: Concept – not built yet

Collects the few health- and diet-related details actually required for accommodation, transfer, and emergency preparedness, on a solid legal basis and in a form that permits sharing with third parties only in abstracted form.

Trigger: Form section “Diet and health” from DAT-020 comes in, or a person subsequently reports a relevant need via DAT-090.

Rule (automatable) Judgment (human decides)

Decision rules

• R1 IF no explicit consent exists AND DSB has not confirmed an alternative legal basis THEN do not store the information, mark the form section as “not answered”, and record no disadvantages for the person.
• R2 IF information must go to third parties THEN only the abstracted value; diagnosis, medication and details do not leave VAULT.
• R3 IF there is an accessibility need THEN HSG-150 must be completed before HSG-080, because room availability determines the allocation and not the other way around.
• R4 IF a need is safety-relevant (example: seizure disorder during a night shoot at a remote work site) THEN inform SFT and PL with the minimum required for the emergency chain and communicate this to the person.
• R5 IF consent is withdrawn THEN delete within 72 hours, remove all derived flags and check whether an existing booking needs to be adjusted (CHG-020).
• R6 IF information relates exclusively to on-site catering and has no travel or housing relevance THEN it is not stored in this library but referred directly to the responsible department.

Common pitfalls

1. Allergies are transmitted to the hotel as a free-text column in the rooming list because the field exists anyway → health data in a broad distribution to a recipient without necessity. 2. Dietary information is copied from the catering list into the travel profile without consent for this purpose → change of purpose without a legal basis. 3. Accessibility needs only become known after room allocation is complete → rebooking within the cancellation period, extra costs and reshuffling half the rooming list. 4. A withdrawal is only noted in the form, but the derived flags remain in place → data is effectively still in use.

Impact H × effort M → Do-first · HITL · RACI **R** THK · **A** PL · **C** DSB, SFT for security-relevant details · **I** HOT and catering exclusively with abstracted values · Manual effort: Estimate: 5–10 min per person with a listed need, plus 20–40 min per case with accessibility or security relevance

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