Privacy Policy

When you are employed by a company covered by a collective agreement stipulating that you must have a pension scheme with PensionDanmark, your employer must pay mandatory pension contributions on your behalf throughout your employment. To this end, your employer will provide us with the following personal data on you together with the contribution:

• Name
• CPR number
• Amount of pension contribution
• Pay period for the pension contribution made
• The collective agreement you are covered by.

When we receive this information, we will establish your pension scheme with the relevant insurances, healthcare scheme and pension savings scheme. Your employer will provide us with the information on a monthly basis so that we can register the contributions made to your pension scheme. To see your pension details, log on to pension.dk.

If you claim benefits under your pension scheme, we will need more personal data from you. If, for instance, you claim a lump sum on critical illness, we will need information about your diagnosis from the hospital.

We provide your CPR number to the Civil Register in order that your name and address may be updated in our systems if you change your address. If the Civil Register has it on record that you are married, we will receive information about your spouse on your death so that we may pay out the death benefit as quickly as possible.

We will also disclose information about your pension scheme to the Danish Tax Agency. We are required by law to do so.

We will sometimes ask third parties for assistance, for instance with making services available to you on our website, and such third parties will also gain access to relevant personal data about you.

We are bound by a duty of confidentiality and must treat all personal data as confidential in accordance with the General Data Protection Regulation (GDPR), the Danish Data Protection Act and other legislation.

We have drawn up the following four Summaries to provide you with a complete overview of the processing of your personal data:

• The collection of personal data from you and others by PensionDanmark and the purpose of processing.
• Who PensionDanmark discloses your personal data to and the purpose of processing.
• The processing of your personal data by PensionDanmark Ejendomme.
• The processing of your personal data by PensionDanmark Uddannelsesfonde.

The GDPR lists the situations in which we may lawfully process your personal data, for instance:

• when you have given consent, see article 6(1)(a) and article 9(2)(a)
• when processing is necessary for compliance with a legal obligation, see article 6(1)(c) and article 9(2)(b)
• when processing is necessary for the performance of our pension agreement with you, see article 6(1)(b), or
• when processing is necessary for the pursuance of other legitimate interests, see article 6(1)(f).

We will process your civil registration number in accordance with section 11 of the Data Protection Act, i.e. when you have given consent or when processing is necessary for compliance with a legal obligation.

Personal data used for the management of your pension scheme are stored under your membership account and are deleted ten years after termination of your membership. This is due to the law of limitation.

Personal data collected and processed with a view to complying with, for instance, the Danish Anti-Money Laundering Act will be deleted five years after termination of your membership.

Partially depersonalised personal data collected for statistical purposes are stored for 30 years after termination of membership.

While we process your personal data in accordance with the law, they are still your data, and you have the rights listed below. However, the rights listed in (7)-(8) can normally not be applied with respect to your pension scheme.

1. When we ask you to give us information, you are entitled to know the purpose for which we need it. The same goes when we collect information about you from others.
2. You are entitled to know which specific information we are processing, for how long we need the information and how we protect your data.
3. If you believe that the data, we have registered about you are incorrect, you are entitled to have them rectified or erased.
4. You are entitled to object to the processing of your personal data
5. You are entitled to have personal data transferred from PensionDanmark to another pension provider, for instance, if you transfer your pension savings.
6. If your claim for insurance benefits is decided automatically, i.e. by means of a robot, you are entitled to have the decision considered by a customer adviser.
7. You are entitled to have your personal data erased.
8. You are entitled to have the processing of your personal data blocked or restricted. If you want to know more about your rights, please contact Customer Service on tel. +45 7012 1330

PensionDanmark seeks to make the content of pension.dk as correct and accurate as possible.

The information, calculations, assessments and estimates provided on this website should not replace the reader’s own assessment of which steps to take in relation to, for instance, the options available through the pension scheme. PensionDanmark assumes no liability for any direct or indirect losses incurred as a result of any transactions made on the basis of information shown at pension.dk.

Pension.dk is protected by copyright and therefore the website may not be reproduced in full or in part without permission.

Information provided by third parties

The external links available on pension.dk are only for your information. PensionDanmark is not responsible for any material produced or otherwise made available by third parties, irrespective of whether this material can be accessed via links on pension.dk. Such third parties must disclose information about themselves that is required by law on their websites and PensionDanmark is not responsible for any non-disclosed or inadequate information.

Data processed

When paying regular mandatory pension contributions on your behalf, your employer provides us with the following information:

• Name
• CPR number
• Pay period for the pension contribution
• Amount of pension contribution
• The collective agreement you are covered by
• Health information and trade union information, if required
• The trainee and training agreement, if required

Purpose of processing

We use the information for purposes of managing the collective agreement’s provision on the obligation to make contributions to PensionDanmark.

We also use the information for purposes of establishing and managing a pension scheme for you that includes the elements provided for by the Labour market parties in the board of directors under the power of attorney to organise.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b)
• Article 9, (2a+b)
• DBSL § 11, par. 2, no. 1 and § 12, par. 1

Data processed

Where contributions are made to your retirement savings scheme, we will disclose your CPR number to Udbetaling Danmark and enquire whether anyone in your household receives income-based public benefits. Udbetaling Danmark will simply answer yes or no.

Purpose of processing

We use the information for purposes of performing the pension agreement with you, i.e. advising you on the implications of contributing to a retirement savings scheme while the household receives income-based public benefits in order for you to decide whether to continue making contributions to the retirement savings scheme.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 9 (2b)
• DBSL § 11, par. 1, no.  1

Data processed

We register your name, e-mail address and telephone number in our meeting planning system. The information is deleted from the meeting planning system six months after the meeting.

Purpose of processing

We use the information for purposes of planning the meeting and contacting you at the agreed time.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6, par.1f

Data processed

You provide us with information relevant to the matter for which you contact us. We make partial use of automated processing, including robotic process automation (RPA) and artificial intelligence (AI), when handling enquiries received via email, Secure Mail, Digital Post, e-Boks, and similar digital communication channels. Such processing is used for the analysis and routing of enquiries to the appropriate advisory teams and to assist our advisers in responding to enquiries.

Purpose of processing

We process your personal data, together with the information we hold regarding your membership, in order to assist you with the matter for which you have contacted us.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6(1)(f) of the General Data Protection Regulation (GDPR) (legitimate interests).

How AI uses your information

When you contact us via “Ask our AI”, we store your conversation with our AI. This chat history contains both the information you provide to the AI and information about you that our AI uses to answer your question. You should therefore not provide your CPR number or other personal information that you do not want us to store as part of the chat history.

Our AI only uses information about you that is necessary to answer your question. The AI has access to certain information about you and can, for example, provide information about your pension savings and insurance cover. It does not have access to health information, such as diagnoses or details of medical conditions. However, it may inform you about the date and time of your next appointment with our Online Doctor service.

The responses are generated automatically by our AI and are not written by an adviser. AI can make mistakes. If you are unsure about a response, we recommend that you contact an adviser or try asking your question in a different way. In some situations, the AI itself will suggest that you contact us.

Our AI can only answer questions. It cannot enter into agreements, change your insurance cover, initiate payments or carry out other actions on your behalf.

Why we use your information

When you contact us via “Ask our AI”, we must, as with other enquiries, be able to document our communication with you. Therefore, we store the chat history.

Only PensionDanmark has access to the chat history. However, you have the right to obtain access to the chat history if you request it. We do not give others access to the chat history, and we do not use it to train AI models.

Legal basis for processing

We process your personal data on the following legal bases:

• EU General Data Protection Regulation Article 6(1)(b) and Article 6(1)(f)
• EU’s General Data Protection Regulation Article 9(2)(h)
• Danish Data Protection Act, Section 8(3)
• Danish Data Protection Act, Section 11(2), no. 2

Data processed

When you call us, we will record the telephone conversation.

Using speech-to-text technology, the audio recording is converted into a text file. The text file is used for an automatic summary of the main content of the conversation in a report using an AI-based language model. 

During the conversation, the advisor is supported by an AI assistant, which automatically provides recommendations on topics that may be relevant to discuss with you.

The recommendations are based on the information we have about your pension conditions and your use of Pension Denmark's products and services.

The recommendations are only used during the conversation with you, but we do store the recommendations you have received from us for a period. It is solely the advisor who assesses and decides how the recommendations are used in the conversation with you.

Purpose of processing

We use the information for purposes of documenting what was discussed and agreed during the telephone conversation.

The information is also used for the purpose of training our customer advisers.

For more information, see pension.dk/en/phone-calls.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6, par. 1b, 1c and 1f
• Article 9, par. 2f

Data processed

You give your name and your customer number or civil registration number to the receptionist.

Your conduct at the reception desk is under video surveillance.

Purpose of processing

We use the information for purposes of preparing the employee assigned to handle your inquiry. 

We use video surveillance to ensure a safe environment for our employees and guests at the reception and to identify burglars.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1f)

Data processed

We register your login information and details about what you use the app and website for – e.g. use of self-service, applications for payment, changing email or mobile number, booking treatment, etc. We also register your usage information for statistical purposes.

Purpose of processing

We use the statistical information for continuous improvements of the app and website.

These statistics can only be accessed by PensionDanmark and are not shared with others.

Our website uses cookies to function. You can learn more about our use of cookies in our cookie policy.

In rare cases, it may be necessary for us to share selected personal information with a partner – e.g. in connection with technical support or troubleshooting. If this happens, the partner acts solely according to PensionDanmark's instructions and cannot use the information for other purposes.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b)
• Article 6 (1f)
• DBSL § 6, par. 1

Data processed

The PensionsInfo report states, among other things, your total insurance cover and your pension savings with your pension providers and the Danish Labour Market
Supplementary Pension Scheme (ATP).

Purpose of processing

When you send us your PensionsInfo report via either pension.dk or pensionsinfo.dk, we will contact you if we do not hear from you.

We assume that you have submitted your PensionsInfo report because you want specific advice.

We will use the information in your PensionsInfo report for purposes of providing the requested advice.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6, par. 1f

Data processed

You disclose your CPR number, name and e-mail address.

Purpose of processing

We use your name and e-mail address for purposes of sending you an invitation to visit the advisory bus to receive personal advice about your pension scheme. We use your CPR number to identify you in our member system in order to advise you based on your specific personal data.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)
• Article 9 (2a)
• DBSL § 11, par. 2, no. 2

Data processed

Separation order or divorce decree and divorce settlement details, i.e.

• Division of pensions
• Former spouse’s name, address, CPR number and pension provider.

Purpose of processing

We use the information for purposes of performing your agreement on the division of yours and your former spouse’s pensions and for transfer of amounts to or from your former spouse’s pension scheme

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b)
• Article 9 (2f)
• DBSL § 11, par 2, no. 4

Data processed

Beneficiary information:

• Name
• CPR number
• Date of birth if a CPR number is not available
• Family connection with you.

Purpose of processing

We use the information for identification purposes to ensure that the lump sum on your death is paid to the beneficiary/beneficiaries you have designated.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b)
• Article 9 (2f)
• DBSL § 12

Data processed

Information on the content of your pension scheme, i.e.

• your insurances
• your pension savings
• your beneficiaries
• the rules applying to your pension savings.

Purpose of processing

You consent to us receiving or disclosing information from/to the transferor/transferee pension provider.

We use the information for purposes of ensuring that the transfer is completed in accordance with applicable tax legislation and the industry agreements on pension transfer to which PensionDanmark is a signatory.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)

Data processed

Information on your choices if:

• You raise or reduce the sum insured
• You adjust your risk profile or select Free Pool Selection (Frit Puljevalg) for your pension savings
• You make private contributions or deposits to the pension savings
• We receive information from Nets when you make extra contributions to your pension savings using your credit card, including information about the bank account used for the payment

Purpose of processing

We register information about your choices under your membership account for purposes of performing the agreement you make with us when you make individual choices in respect of your pension scheme.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b)

Data processed

Tax information – income tax rate.

We obtain information on your income tax rate for as long as we pay pension benefits to you.

Purpose of processing

We are required under tax law to deduct tax from pension benefits.
We use the information for purposes of ensuring correct tax treatment of your pension benefits.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1c)

Data processed

We receive information about the health issues underlying your claim for benefits.

You consent to us collecting information on your specific health issues from, e.g., physiotherapists, chiropractors, your GP, specialists, hospitals, private hospitals, or your municipality.

Purpose of processing

We use the information for purposes of assessing which benefits, if any, you qualify for under the healthcare scheme.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)
• Article 9 (2a)

Data processed

Information about the diagnosis underlying your claim for benefits,

Purpose of processing

You consent to us obtaining information about your diagnosis from, e.g., your GP and the hospital treating you. 

You also consent to us making decisions on an automated basis, i.e. using robots.

We use the information for purposes of assessing whether you qualify for a lump sum on critical illness.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)
• Article 9 (2a)

Data processed
We process the personal data that is necessary in order to handle your case and administer your insurance coverage, including:

• Identification and contact details (e.g. name, Danish personal identification number (CPR number), membership number, address, telephone number and e-mail address).
• Information about your employment and insurance coverage (e.g. position, contributions and scope of coverage).
• Information about your health, earning capacity and loss of earning capacity case (e.g. medical and treatment history, assessments, case status, payments and decisions).
• Information from public authorities, healthcare professionals and other relevant parties (e.g. the municipality, doctors, specialists and your employer).
• Technical information and log data when you use our digital solutions.

Purpose of processing
We process your personal data in order to:

• Assess whether you are entitled to coverage and payments under your insurance for loss of earning capacity.
• Obtain necessary information from public authorities and other relevant parties, when you have given your consent.
• Support case processing using automated tools and AI technology, when you have given your consent.
• Administer your insurance scheme, including follow-up, payments and correspondence.
• Comply with our legal obligations under insurance law and labour market legislation.
• Document and defend our legal interests in the event of disputes.

Legal basis
The processing is carried out in accordance with the General Data Protection Regulation (GDPR) and the Danish Data Protection Act. 
The typical legal bases are:

• Necessity for the performance of your insurance agreement (Article 6(1)(b).
• Necessity for compliance with legal obligations (Article 6(1)(c)).
• Consent, when you have provided it (Article 6(1)(a) and Article 9(2)(a)).
• Processing of health data for the establishment, exercise or defence of legal claims (Article 9(2)(f)).
• Processing of Danish personal identification numbers (CPR number) pursuant to § 11 of the Danish Data Protection Act.

Recipients of data
Your personal data may be disclosed to:

• Public authorities (e.g. the municipality and the Danish Tax Agency).
• Your healthcare providers, specialists, employer and other parties relevant to your case, including partners who help with reactivation, treatment, job retention, or return to work.
• Our partners and data processors who assist us with IT operations, communication, digital case processing and archiving.
• We always enter into data processing agreements to ensure that your personal data is processed securely and in accordance with applicable legislation. Personal data is not transferred to countries outside the EU/EEA without appropriate safeguards.

Retention
We retain your personal data for as long as it is necessary to administer your insurance scheme, process any claims and comply with applicable legal documentation requirements. The data is subsequently deleted or anonymised.

Your rights
Under data protection law, you have the right to:

• Access the personal data we process about you.
• Have incorrect personal data corrected.
• Have your personal data erased in certain cases.
• Restrict our processing of your personal data.
• Object to processing based on legitimate interests.
• Receive your personal data in a structured, commonly used and machine-readable format (data portability).
• Withdraw your consent with effect for the future, where processing is based on consent.

Obligation to provide data
You may choose not to provide the information we request. However, in that case we will not be able to process your case or pay benefits under your insurance.

Automated processing and AI
In certain cases, we use AI technology to support case processing. However, no decisions are made solely on the basis of automated processing. An assessment is always carried out by a human before a decision is made.

Data processed

The decision on granting of a resource programme.

Information on the health issues underlying the granting of the resource programme.

Purpose of processing

You consent to us obtaining this information from your municipality.
You also consent to us making decisions on an automated basis, i.e. using robots.
We use the information for purposes of assessing whether you qualify for 50% of the lump sum on anticipatory disability pension.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)
• Article 9 (2a) 

Data processed

Decision on granting of a subsidised flexi-job.

Information on the health issues underlying the granting of the subsidised flexi-job.

Purpose of processing

You consent to us obtaining information about your subsidised flexi-job from your employer and the job centre in your municipality.
You also consent to us making decisions on an automated basis, i.e. using robots.
We use the information for purposes of assessing whether you qualify for savings balance protection on the granting of a subsidised flexi-job.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)
• Article 9 (2a)

Data processed

Decision on award of public anticipatory disability pension or senior pension. Information on the health issues leading to the award of public anticipatory disability pension or senior pension. Supplementary Labour Market Pension contributions.

Purpose of processing

You consent to us obtaining information concerning your pension case from your municipality and the senior pension entity.

We use the information for purposes of assessing whether you qualify for insurance benefits on anticipatory disability pension or senior pension and for purposes of establishing a Supplementary Labour Market Pension scheme with PensionDanmark.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)
• Article 9 (2a)

Data processed

The Danish Transport Authority’s decision on suspension of licence and the health issues leading to the loss of licence.

Information in the termination letter from your employer.

Purpose of processing

You consent to the Danish Union of Railwaymen sending the Danish Transport Agency’s decision, your health information and the termination letter from your employer to PensionDanmark.

We use the information for purposes of assessing whether you qualify for a lump sum on loss of licence.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1a)
• Article 9 (2a) 

Data processed

Information from the Civil Register on your permanent exit from Denmark, photo ID such as copy of passport and bank details.

You are required by law to submit photo ID.

Purpose of processing

You are required under the Danish AML Act to submit photo ID. We use the information for purposes of assessing whether you qualify for a resigning member refund, which is conditional on your permanent exit from Denmark.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b)
• Article 6 (1c)
• DBSL § 12

Data processed

We retrieve the date of death from the Civil Register.

The probate court, the beneficiary, the beneficiary’s lawyer, the administrator or the estate’s contact person provide us with the rest of the information, e.g.

• names, addresses, CPR numbers and family connections of:
• named beneficiary
• heirs if the beneficiary is your ”next of kin”.
• any heirs objecting to the beneficiary designation
• guardian + information on trust institution in case of beneficiary under age.
• documentation, e.g. proof of residence certificate, certificate of baptism, etc. 
• photo ID, where relevant.

Purpose of processing

We use the information for purposes of performing our agreement with you concerning payout to your beneficiary.

If the beneficiary is your “next of kin”, we will assess who is entitled to receive insurance benefits on your death pursuant to the Insurance Contracts Act and obtain the necessary documentation.

We are required under tax law to deduct state tax and, where relevant, estate tax from the lump sum.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b)
• Article 9 (2f)
• DBSL § 11, par. 2, no. 4

Data processed

When you file a complaint with the Danish Insurance Complaints Board, you consent to the Insurance Complaints Board disclosing your information to PensionDanmark and collecting information from PensionDanmark and other relevant parties in order to decide the complaint.

Purpose of processing

When we are notified that you have filed a complaint with the Insurance Complaints Board, we will send a reply stating the reasons for the decision you are complaining about.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL): 

• Article 6 (1a)
• Article 9 (2a)

Data processed

Information received from your employer for purposes of establishing your pension scheme and subsequently health information etc.

The information will depend on the material for which it is to be used.

Purpose of processing

PensionDanmark is required to inform its Board of Directors about the management of the pension scheme to enable the Board to fulfil its statutory obligations, and we are subject to a range of statutory requirements, for instance that the company’s funds must be sufficient to cover the benefits payable to our members. For this reason, pension scheme statistics are prepared on an ongoing basis.

Your personal data are included – in anonymous form – in board reports and statistics.

If, for instance, we are to inform the Board of Directors of the number of pension scheme members, you will be included in that number.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL): 

• Article 6 (1c)
• Artikel 9 (2b)

The purpose for which the recipient uses your data

If you or your beneficiaries need help from a lawyer or an administrator, we will provide the lawyer/administrator with the personal data requested.

The purpose for which the recipient uses your data

We will disclose your name and CPR number to your employer if we need information about your employment relationship, e.g. whether you are in a subsidised flexi-job, a re-employment programme or a wage subsidy job, for purposes of assessing whether you are covered by anticipatory disability pension or senior pension insurance.

The purpose for which the recipient uses your data

If an employer fails to make collectively agreed pension contributions to PensionDanmark on behalf of its employees, even if we send a reminder, we will notify the relevant trade organisations of the pension contributions missing for each individual member for purposes of disputes procedures.

The purpose for which the recipient uses your data

Under your pension agreement, all benefits will be paid into your NemKonto. If a foreign member does not have a NemKonto, we will for identification purposes disclose that member’s name, address and account number (which the member has disclosed to us) together with the amount of the benefits to the member’s bank.

The purpose for which the recipient uses your data

If you transfer your pension scheme to or from PensionDanmark, we will disclose information about your pension savings through an IT system owned by Insurance & Pension Denmark.

The purpose for which the recipient uses your data

We disclose your CPR number. The Civil Register uses the information to notify us of any changes to your address or marital status (whether you have married, divorced, etc.) and of the date of your death. On your death, we will also receive information on your spouse, if relevant.

The purpose for which the recipient uses your data

PensionDanmark needs to be able to make calculations for risk assessments, the fixing of premiums and payout rates and other statistics necessary for the management of collectively agreed labour market pension schemes, and to that end needs to access data from Statistics Denmark.

The purpose for which the recipient uses your data

Where you have consented to us obtaining information in connection with your request for assistance from the healthcare scheme or for critical illness insurance benefits, we will disclose your CPR number and name to enable your GP to identify you and provide us with the information we have requested.

The purpose for which the recipient uses your data

If you or your beneficiaries need help from your trade union, we will provide the union with the requested information if you or your beneficiaries have consented to the information being disclosed to the union.

The purpose for which the recipient uses your data

We will provide information about a deceased member to the population register of the member’s municipality of residence and/or the Danish National Archives. The population register of the member’s municipality of residence and/or the Danish National Archives will use the information to identify the deceased member’s intestate heirs where the lump sum on death is to be paid to the member’s next of kin.

The purpose for which the recipient uses your data

For purposes of performing the pension agreement in respect of a number of Falck Danmark employees, we provide FG with these employees’ CPR numbers on a regular basis inasmuch as FG manages disability pensions on behalf of PensionDanmark. 

FG uses these CPR numbers to set up and manage memberships for employees receiving temporary disability pension and to pay out temporary and permanent disability pension benefits.

The purpose for which the recipient uses your data

If the benefits payable on your death are to be paid to a beneficiary under age and the amount is to be deposited with an approved trust institution, we will inform the trust institution of the beneficiary’s CPR number, name and address and the relevant amount for purposes of the institution’s identification of the beneficiary and its management of the funds until the beneficiary comes of age.

As it is the guardian who decides which trust institution will manage the funds, we will also provide the trust institution with the guardian’s CPR number, name and address.

The purpose for which the recipient uses your data

Where you have consented to us obtaining information in connection with your request for assistance from the healthcare scheme or for insurance benefits, the municipality will use that information to identify you and provide us with the information we have requested.

The purpose for which the recipient uses your data

For purposes of performing the pension agreement, we provide a list of our members’ CPR numbers to SDST on a monthly basis. If you are registered with LPR as having a diagnosis covered by critical illness insurance, SDST will write to you to encourage you to contact us in order to have the lump sum on critical illness paid out.

The purpose for which the recipient uses your data

PensionDanmark sends all your letters by digital mail, and you can also access them on pension.dk.

The purpose for which the recipient uses your data

We provide Rambøll with members’ names, addresses and telephone numbers and information concerning their relevant use of self-service solutions on pension.dk when we wish to survey members about our services in connection with, for instance, Prompt Diagnosis, claims for insurance benefits, etc.

Rambøll uses this information for purposes of conducting phone interviews with members on behalf of PensionDanmark and, on that basis, preparing a member satisfaction report for PensionDanmark.

PensionDanmark also uses Rambøll’s system for sending out user surveys and questionnaires. Therefore, for members who sign up for PensionDanmark’s user panel, information about their names and email addresses is processed in Rambøll’s system, as well as the responses they provide via email and in forms.

The purpose for which the recipient uses your data

We provide the vendor with your name, address, date of birth and country of residence. Under the Danish Anti-Money Laundering Act, we are required to prevent and combat money laundering and terrorist financing by, for instance, identifying and applying due diligence measures in respect of our members. This includes investigating whether among our members there are so-called ”politically exposed persons” or persons who appear on international lists of known terrorists. The vendor supplies the solution we use to check this.

The purpose for which the recipient uses your data

We disclose your name and address. The vendor uses this information for purposes of finding your telephone number if we do not already have it and need to call you in connection with, for instance, your enrolment in the pension scheme.

The purpose for which the recipient uses your data

DEAS handles the management of properties on behalf of PensionDanmark.

For more information about the processing of personal data, see the section about PensionDanmark Ejendomme below.

The purpose for which the recipient uses your data

PensionDanmark uses IT vendors and collaboration partners who perform IT-related tasks for us.

These partners may process your personal data when it is necessary in order for them to perform the task in question for PensionDanmark. 

PensionDanmark protects your personal data and ensures that a high level of IT security and data protection is maintained by our data processors as well.

The purpose for which the recipient uses your data

Most of the data controllers and data processors listed above are located in the EU/EEA. Where one or more of the data controllers/data processors are located in countries outside the EU/EEA, your personal data will only be transferred to such data controllers/data processors if the EU Commission has specifically classified the country in question as “safe”.

A list of the relevant data controllers/data processors and the countries outside the EU/EEA to which we may transfer your personal data is available on request from our data protection officer.

The purpose for which the recipient uses your data

Where you have consented to this, we will disclose information about your pension scheme with PensionDanmark to your new pension provider in case you wish to transfer your pension savings. The pension company will use your insurance and pension information for advisory purposes and for management of the amount transferred.

The purpose for which the recipient uses your data

In connection with the reconstruction or bankruptcy of an undertaking, PensionDanmark will on request disclose information to the relevant trade union, including CPR numbers, names and contribution details of the employees affected, for purposes of the trade union’s filing of proof of claims against the Employees’ Guarantee Fund on behalf of the employees concerned.

The purpose for which the recipient uses your data

Under your pension agreement, all benefits will be paid into your NemKonto. We will disclose your or your beneficiary’s CPR number to NemKonto together with the amount of the benefits. Your account number is not known to us.

The purpose for which the recipient uses your data

If you receive a lump sum payment for a critical illness diagnosis, covered by one of the patient associations we collaborate with, and you give consent, we will send information about your name, address, and phone number to the relevant patient association. This entitles you to one year of free membership in the patient association. The patient association uses the information to set up a one-year free membership for you and to contact you about the contents of the membership.

The purpose for which the recipient uses your data

We will inform PensionsInfo that you have a pension scheme with PensionDanmark – and if you use PensionsInfo, we will provide PensionsInfo with your insurance and savings details so that they may prepare a complete overview of your insurances and pension savings.

The purpose for which the recipient uses your data

We disclose information on member contributions to and benefits from the pension scheme and on the taxes deducted from benefits. The Tax Agency uses the information for purposes of checking members’ pension information.

The purpose for which the recipient uses your data

We need to inform the probate court of the amount payable on your death and of your beneficiary. 

When we make payments to beneficiaries, we need to send a statement of the lump sum paid on death to the probate court to enable it to check whether PensionDanmark has deducted and paid the correct amount of estate tax.

The purpose for which the recipient uses your data

Where you have consented to us obtaining information in connection with your request for assistance from the healthcare scheme, we will disclose your CPR number and name to enable the social worker to identify you and provide us with the information we have requested.

The purpose for which the recipient uses your data

For purposes of performing the pension agreement, we provide a list of our members’ CPR numbers to STAR on a monthly basis. If you are on long-term sick leave or are in a subsidised flexi-job, STAR will write to you to encourage you to contact us in order to get help from the pension scheme. We are
permitted by law to disclose the information to STAR.

We also provide STAR with information about your pension savings six months before the date when you qualify for early retirement benefits. This information is passed on to the relevant unemployment insurance fund for purposes of its calculation of the amount of early retirement benefits inasmuch as pension savings are offset against early retirement benefits.

The purpose for which the recipient uses your data

PensionDanmark provides STIL with CPR numbers on an ongoing basis, and STIL subsequently informs PensionDanmark Pensionsforsikringsaktieselskab and PensionDanmark Uddannelsesfonde (= PensionDanmark) of which courses you have attended.

PensionDanmark enters this information on your password-protected page on pension.dk under ”supplementary training” to provide you with an overview of your training and employment history (your profile).

You are also notified of relevant courses so that you and your employer can make arrangements, for instance for how you can train to be a skilled worker.

The purpose for which the recipient uses your data

Where you have consented to us obtaining information in connection with your request for assistance from the healthcare scheme, we will disclose the information provided by you to the healthcare professional who will be treating you to enable the healthcare professional to identify and treat you and register such information as is required by law.

Healthcare professionals: specialists, hospitals, private hospitals, therapists, online doctors and online psychologists.

The purpose for which the recipient uses your data

We provide Udbetaling Danmark with your CPR number in order that they may inform us whether or not the household receives public income-based benefits, which information is used for purposes of our advice on retirement savings contributions.

The purpose for which the recipient uses your data

For purposes of performing the pension agreement, we provide a list of our members’ CPR numbers to Udbetaling Danmark on a monthly basis. If you have been awarded public anticipatory disability or senior pension, Udbetaling Danmark will write to you to encourage you to contact PensionDanmark in order to have insurance benefits paid out.

Where you have consented to us disclosing information about you in connection with a claim for insurance benefits, Udbetaling Danmark will use that information to make the municipality’s and your monthly contribution to your Supplementary Labour Market Pension Scheme with us.

Personal data

Members of PensionDanmark have a first claim to some of PensionDanmark Ejendomme’s rented homes. Subject to your consent, we will send you an e-mail whenever a relevant unit, based on the information you have provided regarding your age, marital status, current residence, etc., becomes available, in which case the processing will take place based on your consent pursuant to article 6 (1) (a) of the GDPR.

Personal data

If you rent a home from PensionDanmark, we may process general personal data about you, such as name, address, e-mail address, IP address, telephone number, title, professional and educational information, family status, photos, images, video footage of the property, payment information and information on your special connections, if any, under current grant rules (member number or the like). We may also process your CPR number. The processing will be based on article 6(1)(b) of the GDPR and section 11(2)(iii) of the Danish Data Protection Act.

The information is processed solely for purposes of our management of the rental properties, including waiting list registrations, signing of leases, management of leases and premises, registration of user information with utilities (for example in connection with your moving in or out), digital communications and collection of outstanding rent payments.

As a general rule, PensionDanmark will not process sensitive personal data about you in connection with the letting of homes. However, if required by special circumstances, PensionDanmark may process sensitive personal data such as information about your health, but we will only do so at your request. This will typically only be relevant where the premises need to be made disabled-friendly. Such processing will be based on article 9(2)(b) of the GDPR. Moreover, in the event that a criminal offence is committed in connection with the premises, PensionDanmark may process information about such offence in pursuance of section 8(3), second sentence, of the Data Protection Act.

PensionDanmark will keep the information throughout the term of the lease and for as long as is necessary after termination of the lease in accordance with applicable legislation. For example, information that is relevant for the establishment of any legal claims will be kept after termination of the lease. We do so for purposes of pursuing our legitimate interests in keeping such information until expiry of the limitation period under the provisions of the Danish Statute of Limitations Act.

PensionDanmark has made a property management agreement with DEAS A/S, Dirch Passers Allé 76, 2000 Frederiksberg, Denmark, under which DEAS manages the properties on behalf of PensionDanmark. In this connection, PensionDanmark and DEAS have entered into a data processing agreement, under which DEAS is required to process any personal data on behalf of PensionDanmark in accordance with applicable legislation.

Personal data

If you buy a home from PensionDanmark, PensionDanmark may process general personal data about you, such as name, address, e-mail address, telephone number and account details. We use this information to identify you as the buyer of the unit in question, and we need it to make and perform the purchase agreement with you, see article 6 (1) (b) of the GDPR.

In addition, PensionDanmark may process information (see article 6(1)(b) of the GDPR) on your consumption of water, heating and electricity, including meter number and consumption numbers. As the buyer, you are required under the purchase agreement with PensionDanmark to provide us with such information as is necessary to enable registration of the transfer of ownership with the relevant utilities and consumption settlement with the right owner. In this connection, PensionDanmark will only disclose such personal data about you as are required to notify the utilities of the transfer of ownership. This includes name, address, meter number and consumption numbers. The transfer of ownership cannot be completed without disclosing this information.

The personal data concerning your consumption are disclosed only to the relevant utilities supplying your home. PensionDanmark will keep the consumption data for a period of time after the transfer of ownership has been registered with the utilities in order to be able to document both our and your rights and obligations vis-à-vis the utilities with respect to consumption settlement. We do so for purposes of pursuing our legitimate interests in keeping such information until expiry of the limitation period under the provisions of the Statute of Limitations Act.

PensionDanmark will keep the data for a period of time after completion of the sale, as permitted by applicable legislation, following which the data will be erased. We keep the data to be able to document any legal claims between you and PensionDanmark until expiry of the mandatory time limit.

In connection with the transfer of ownership, including its registration with the relevant utilities, PensionDanmark may be represented by DEAS A/S, Dirch Passers Allé 76, 2000 Frederiksberg, Denmark, tel. +45 7030 2020, in its capacity as property manager. PensionDanmark and DEAS have entered into a data processing agreement, under which DEAS is required to process any personal data on behalf of PensionDanmark in accordance with applicable legislation.

Personal data

PensionDanmark’s representative will provide the buyer with a copy of the handover protocol and the list of defects as soon as possible. By signing the protocol, the buyer authorises PensionDanmark or its representative to notify the utilities of the transfer of ownership.

In connection with such notification, PensionDanmark will be the controller in relation to any personal data about you which PensionDanmark receives and discloses to the utilities. PensionDanmark needs to process these personal data in order to notify the utilities of the transfer of ownership so that the consumption may be settled with the right owner, and to properly perform the purchase agreement between PensionDanmark as the seller and you as the buyer as well as the handover protocol, see article 6(1)(b) of the GDPR.

In this connection, PensionDanmark will only process such personal data about you as are necessary to be able to notify the utilities of the transfer of ownership. The data may include the following information: Name, address, meter number and consumption numbers.

Under the purchase agreement, you are required to provide PensionDanmark with this information to enable us to register the transfer of ownership with the relevant utilities. The transfer of ownership cannot be completed without disclosing this information. Your personal data are disclosed only to the relevant utilities supplying your home.

PensionDanmark will keep your personal data for a period of time after registration of the transfer of ownership with the utilities for purposes of pursuing our legitimate interests in being able to document both our and your rights and obligations vis-à-vis the utilities with respect to consumption
settlement until expiry of the limitation period under the relevant provisions of the Statute of Limitations Act.

In connection with the transfer of ownership, including its registration with the relevant utilities, PensionDanmark may be represented by DEAS A/S, Dirch Passers Allé 76, 2000 Frederiksberg, Denmark, tel. +45 7030 2020, in its capacity as property manager. PensionDanmark and DEAS have entered into a data processing agreement, under which DEAS is required to process any personal data on behalf of PensionDanmark in accordance with applicable legislation.

Data processed

On a regular basis, your employer provides us with, and we process the
following information about you:

• Name
• E-mail address
• Age
• Employer (current)
• Position (current)
• Industries (current and previous)
• Skills (acquired in current and previous positions)
• Course participation history (ongoing and previous course programmes)
• Proposals for supplementary training and other course programmes
• CPR number.

For union representatives, also:

• Trade union affiliation

Purpose of processing

To collect collectively agreed contributions for funds from companies and pay lost wage subsidies to companies in connection with employee participation in supplementary training.

To process funding applications for training activities and planning of course programmes. To manage the data controller’s agreement with employee and employer organisations. 

To provide an overview of supplementary training options and assist employees and companies in planning training activities.

To perform analysis to ensure the funds support relevant supplementary training offers as best as possible.

To provide employees with easy access to documentation of their completion of relevant supplementary training (course certificates).

To support the Danish government’s Commission for Second-generation Reforms via the Ministry of Children and Education (via Statistics Denmark’s researcher scheme)

We are permitted to process your personal data under the following provisions:

• Article 6 (1) (a) and (b) of the GDPR
• Section 11 (2) (iv), cf. section 7 (2) and section 12 (1), of the Data Protection Act.

When a healthcare professional in PensionDanmark, hereafter referred to as 'the Healthcare Professional', during telephone health counseling assesses, that you should be referred to Online Physiotherapy, the healthcare professional forwards your information to the therapist in Online Fysioterapi Denmark K/S, hereafter referred to as 'the Therapist', who will contact you and manage the treatment of your ailments or issues in the musculoskeletal system.

The healthcare professional forwards the following personal information to the therapist: 

• Name
• CPR number
• Contact information
• Information about your ailments and issues that form the basis for the referral

The therapist creates a medical record for you and enters the aforementioned information therein.

The therapist continuously updates your medical record about the treatment process, including the type of treatment.

The medical record is deleted no earlier than 5 years after the last entry in the record.

The video meeting is audio recorded. The audio recording is stored for three months, after which it is deleted.

Purpose of the processing

Based on your information, including visual observations, the therapist will recommend and show you how your ailments/issues can be alleviated through, for example, targeted physical exercises that you can perform at home.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b) and Article 9 (f)
• DBSL § 11, par. 2, no. 4 and § 7. par. 2

PensionDanmark can process personal data that is loaded into the IT systems used in the task solution at Online Physiotherapy Denmark K/S in connection with the operation and maintenance of IT system support in collaboration with IT suppliers and partners.

This means that your personal data can be processed by these suppliers when necessary.

Purpose of the processing

PensionDanmark manages the ongoing IT system support and maintenance in collaboration with IT suppliers and partners.

PensionDanmark protects your personal data and ensures that an appropriate level of IT security and data protection is maintained, including by data processors.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b) and Article 9 (f)
• DBSL § 11, par. 2, no. 4 and § 7. par. 2

When a healthcare professional in PensionDanmark, hereafter referred to as ‘the Healthcare Professional’, during telephone health counselling assesses that you should be referred to Online Psychologist, the Healthcare Professional forwards your information to the psychologist at Online Psykolog Danmark K/S, hereafter referred to as ‘the Psychologist’, who will then contact you and provide counselling and treatment. If your health scheme covers Online Psychologist, you may also book an appointment directly via pension.dk or in PensionDanmark’s app. In these cases, the information you enter yourself during the booking process is forwarded to the Psychologist for the purpose of planning and carrying out the treatment.

When you have been referred to Online Psykolog Danmark K/S or have booked an appointment, the following personal data is forwarded to the practitioner:

• Name
• CPR number
• Contact information
• Information about the reason for your enquiry, including your answers to questions asked in connection with booking the first consultation
• WHO-5 response

The Psychologist creates a medical record for you and enters the aforementioned information therein.

The Psychologist continuously updates your medical record regarding the course of treatment, including the type of treatment.

All medical records / all medical record material are stored in accordance with the Executive Order on Authorised Healthcare Professionals’ Patient Records, according to which medical record data must be stored for a minimum of 10 years.

The consultation between you and the Psychologist is audio recorded. The audio recording is stored for up to three months, after which it is deleted. The recording is converted using speech-to-text technology into a text file, which is used to automatically generate a brief summary of the key content of the conversation for the medical record using an AI-based language model. The text file created on the basis of the audio recording is stored in anonymised form for 10 years.

Purpose of the processing
Based on your information, including what you share during the consultations, the Psychologist provides professional psychological counselling and treatment of your psychological challenges. As part of the treatment process, the Psychologist may provide you with tools, strategies, or home assignments/exercises which, between consultations, can support you in managing your challenges.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b) and Article 9 (f)
• DBSL § 11, par. 2, no. 4 and § 7, par. 2

PensionDanmark can process personal data that is loaded into the IT systems used in the task solution at Online Psykolog Danmark K/S in connection with the operation and maintenance of IT system support in collaboration with IT suppliers and partners.

This means that your personal data may be processed by these suppliers when necessary.

Purpose of the processing
The Psychologist uses the information processed in the IT systems used to be able to provide professional psychological counselling and treatment, including planning of consultations, record keeping, and, where relevant, the preparation of psychological exercises as part of the treatment process.

Provision in the General Data Protection Regulation (article no.) and paragraph in the Danish Data Protection Act (DBSL):

• Article 6 (1b) and Article 9 (f)
• DBSL § 11, par. 2, no. 4 and § 7, par. 2