Categories of data subjects: Overview, definition, and example
What are categories of data subjects?
Categories of data subjects refer to the different types of individuals whose personal data is collected, used, or processed by a business or organization. These categories are typically based on the person’s relationship to the organization—such as employees, customers, job applicants, or website visitors. Identifying these categories helps companies understand who they’re collecting data from and is often required by privacy laws and data protection policies.
Why are categories of data subjects important?
These categories are important because they help businesses assess privacy risks, structure privacy notices, and meet legal obligations under regulations like the GDPR, CCPA, and others. Each category may involve different types of data and require different protections. For example, employee data often includes sensitive information like Social Security numbers or health data, while data from website visitors may be limited to IP addresses or browsing behavior.
Understanding categories of data subjects through an example
A software company may process personal data from the following categories of data subjects:
- Employees (HR and payroll records)
- End users (account creation, support interactions)
- Prospective customers (leads and demo requests)
- Contractors (contractual and payment information)
- Website visitors (analytics and cookies)
Mapping out these categories allows the company to tailor its privacy practices and document its compliance efforts.
Example of how a categories of data subjects clause may appear in a contract
Here’s how a categories of data subjects clause may appear in a contract:
"The Processor shall process Personal Data only in relation to the following categories of Data Subjects: employees, customers, contractors, and website visitors of the Controller, as further described in Annex 1."
Conclusion
Categories of data subjects are a foundational part of data protection planning. They help organizations understand whose data they are handling, assess risk more accurately, and fulfill disclosure and accountability obligations under privacy laws. Including this information in contracts—especially in data processing agreements—provides clarity and supports responsible data governance.
This article contains general legal information and does not contain legal advice. Cobrief is not a law firm or a substitute for an attorney or law firm. The law is complex and changes often. For legal advice, please ask a lawyer.