Sports, leisure and fitness businesses who process data gathered from wearable or similar electronic devices should look carefully at their obligations under the new proposed data protection regime, especially with regard to the need for Privacy Impact Assessments ("PIAs.").
The Regulation in its current draft form requires the carrying out of a PIA where, "a type of processing, in particular using new technologies, and taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk for the rights and freedoms of individuals" (Article 33).
So, whether the technology in question is being used to gather data concerning health, location data or any other kind of personal data, enterprises will need to consider whether this requirement will apply. An impact assessment will be mandatory if the processing in question is likely to result in a high risk for data subjects’ rights and freedoms.