Vital interests is one of the six legal bases for processing personal data under the GDPR (Article 6(1)(d)), applicable when processing is necessary to protect the life or critical health interests of the data subject or another natural person. This basis is intended for emergency situations where the individual is unable to give consent, such as medical emergencies or natural disasters. It is narrowly interpreted and cannot be used as a general justification for health-related data processing.
In practice, reliance on vital interests as a legal basis is rare and typically limited to life-threatening scenarios. Organisations in the healthcare and emergency services sectors should understand when this basis applies but should not treat it as a substitute for obtaining proper consent or establishing another more appropriate legal basis. Documenting the circumstances under which vital interests are invoked is essential for demonstrating compliance.