We are acting for a client who is developing a mobile app/video game which it is proposed will incorporate the names and nationalities of sportspeople that are in the public domain. What are the data protection risks of using this type of data? Further, what mitigating steps could be taken to reduce any risk?

We are acting for a client who is developing a mobile app/video game which it is proposed will incorporate the names and nationalities of sportspeople that are in the pubic domain. What are the data protection risks of using this type of data? We are aware that data being in the public domain does not of itself mean that it will be lawful to process it, and we are also conscious that nationalities could be deemed to reveal ethnic or racial origin and therefore comprise "special category data". However, this information generally appears on official sources (for example, league and club websites, live broadcasts, and so on) and so can it reasonably be assumed that the data subjects have agreed to make the information public? Further, what mitigating steps could be taken to reduce any risk?