(A) The (special) personal data are already in the possession of the tax authorities.

The "Advice on Data Foundations & Analytics" report (October 2024) from the Advisory Committee on Analytics specifically addresses the following: "The question is whether collecting additional (special category) personal data is a logical step, given the legal limitations, when there is insufficient data available to identify bias. When additional data, including (special category) personal data, are used for a comprehensive analysis of the cause of bias, we see two scenarios: (A) The (special category) personal data is already in the possession of the tax authorities. (B) The agency obtains new (special category) personal data." (p. 14)

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