Matthew Holman, Principal at EMW LAW, explains how under the GDPR, any company that extrapolates data will need to identify legal grounds for processing that data, specifically HR departments that often hold sensitive data. Holman explains how the requirements for processing of sensitive personal data, relating to race, sex, disability, age, religion/belief and more, are issues that HR teams will need to be especially careful. He also addresses employee recruitment, noting that If you post adverts and a candidate comes to you, then they are declaring an interest. However, if you want to communicate to someone/headhunt them, you need their consent first. Its advisable to have a mechanism in place which makes it extremely clear to the consumer that they know exactly what theyre opting in to.