Abstract
<jats:title>Abstract</jats:title> <jats:p>This case study presents a legal assessment of the proportionality of processing sensitive data for scientific research purposes in the event of a pandemic. The specific case involves the processing of viral sequence data obtained from samples tested positive for SARS-CoV-2 at COVID-19 test sites and of other case-related data by a public research institute. The case is presented in the style of a simplified proportionality assessment carried out when applying the relevant paragraphs of the General Data Protection Regulation. The study highlights the main steps of the proportionality test and characterizes them by emphasizing the most significant arguments related to those steps. On the one hand, particular priority is given to the interests of the data subject, which become multipolar in the context of data processing in a pandemic research setting. On the other hand, technical measures to mitigate risks are prioritized both in preparation for the proportionality assessment and in response to its findings. By providing a better understanding of the factors that influence the proportionality test in the processing of scientific research data, the present case study contributes to a standardization of the test, which in turn can simplify legal decisions related to the authorization and oversight of specific, pandemic-related data processing operations, including international data transfers.</jats:p>