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Understanding GDPR requirements for a guide: types of data collected (including medical data), legal basis, consent, retention periods and security best practices.
As a guide, you collect a great deal of information about your clients, some of which may be medical in nature. The GDPR and applicable data protection laws govern this reality: understanding the basics lets you act with confidence.
This guide does not replace legal advice. For specific questions (trips, expeditions, working abroad), do not hesitate to consult a legal professional or the resources provided by your professional association or insurer.
In the course of your activity, you generally collect the following information:
All of this information falls under "personal data", and health data is considered sensitive data under the GDPR. It requires particular care.
The GDPR requires you to define a "legal basis" for each processing of personal data. For a guide, the main ones are:
For health data, the rule is stricter: processing is in principle prohibited, except in certain cases (vital interest, medical purposes, etc.) or with explicit consent from the individual concerned.
In practice, if you collect health information to adapt the outing and ensure safety (allergies, contraindications, treatments), it is prudent to:
The GDPR requires that data not be kept "longer than necessary". A few commonly accepted benchmarks (to be adapted with legal advice if needed):
What matters most is to define clear rules (even simple ones), document them in your privacy policy, and have a practical way to apply them.
Your clients have rights over their data. They can request:
In practice, you must inform your clients how to exercise these rights (contact email, form, postal address) and respond within a reasonable timeframe (generally one month).
A privacy policy accessible on your website or sent with your client form is a good way to explain these points.
The GDPR also emphasises security. Even without being a technical expert, you can already avoid a number of risks with a few good habits:
In the field, you can also minimise what you carry: for example, only access the information truly needed for the outing (emergency contact, serious allergies), rather than the entire detailed history.
A specialised tool like GuideMate does not replace your responsibility as a "data controller", but it can help you implement certain best practices more easily:
The goal is to move from a pile of emails and notebooks to a more coherent system, where you know what you collect, why, where it is stored and for how long.
Can I still use a simple paper notebook?
Yes, the GDPR does not require you to use a digital tool. However, even on paper, you remain responsible for the security and confidentiality of the information (do not leave the notebook lying around, limit sensitive data, destroy old pages that are no longer needed, etc.).
Do I need written consent for all collected data?
Not necessarily. For data required to perform the contract (identity, contact details, practical information), the legal basis can be the contract itself or your legitimate interest. However, for health data, explicit consent is strongly recommended, with a clear statement of the purpose (safety of the outing).
I'm just a "small" guide — does the GDPR really apply to me?
Yes, as soon as you process personal data, regardless of the size of your business. The good news is that simple measures (collect less, store better, inform your clients, delete what is no longer needed) already cover a large part of what is expected.
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