In thinking about the legal arrangements for Jisc's learning analytics services we consciously postponed incorporating medical and other information that Article 9(1) of the General Data Protection Regulation (GDPR) classifies as Special Category Data (SCD): "personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation" (mo