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Data Processing Notice

Data Processing Notice Template for Denmark

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Data Processing Notice

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Document background
The Data Processing Notice is a mandatory document required under both the EU General Data Protection Regulation (GDPR) and Danish data protection law. It must be provided to data subjects when collecting their personal data, whether directly or indirectly. The notice ensures transparency in data processing activities and helps organizations meet their obligations under Article 13 and 14 of the GDPR, as implemented in Denmark through the Data Protection Act. It should be used whenever an organization processes personal data of Danish residents or operates within Denmark, and must be written in clear, plain language that is easily understandable by the average person. The notice needs regular review and updating to reflect any changes in processing activities or regulatory requirements.
Suggested Sections

1. Identity and Contact Details: Information about the data controller and their representative, including contact details of the Data Protection Officer if applicable

2. Categories of Personal Data: Description of the types of personal data being processed

3. Purposes of Processing: Explanation of why the personal data is being processed and the legal basis for each purpose

4. Recipients of Personal Data: Information about who will receive or have access to the personal data

5. Data Retention: How long the personal data will be stored, or the criteria used to determine this period

6. Data Subject Rights: Information about rights under GDPR including access, rectification, erasure, and data portability

7. Right to Lodge Complaints: Information about the right to lodge a complaint with the Danish Data Protection Agency

8. Source of Data: Where the personal data comes from, if not collected directly from the data subject

Optional Sections

1. International Transfers: Include when personal data is transferred outside the EU/EEA, describing transfer mechanisms and safeguards

2. Automated Decision Making: Include when automated decision-making or profiling is used, explaining the logic and consequences

3. Statutory/Contractual Requirements: Include when providing personal data is a statutory or contractual requirement

4. Further Processing: Include when personal data might be processed for purposes other than those initially collected for

5. Specific Processing Activities: Include when certain types of processing require additional explanations (e.g., CCTV monitoring, employee monitoring)

Suggested Schedules

1. Detailed Processing Activities: Comprehensive list of processing activities, purposes, and legal bases

2. Technical and Organizational Measures: Details of security measures implemented to protect personal data

3. Cookie Policy: Detailed information about the use of cookies and similar technologies

4. Third Party Recipients: Detailed list of third parties who receive personal data and their roles

5. Data Retention Schedule: Detailed retention periods for different categories of personal data

Authors

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Relevant legal definitions
Personal Data
Processing
Data Subject
Data Controller
Data Processor
Special Categories of Personal Data
Consent
Legitimate Interest
Data Protection Officer
Supervisory Authority
Danish Data Protection Agency
Third Party
Recipient
Filing System
Cross-border Processing
Personal Data Breach
Profiling
Pseudonymisation
Data Minimisation
Storage Limitation
Automated Decision-Making
Data Protection Impact Assessment
Transfer
Legal Basis
Cookie
Log Data
Technical and Organizational Measures
Privacy by Design
Privacy by Default
Data Protection Legislation
Relevant Industries
Relevant Teams
Relevant Roles
Industries
General Data Protection Regulation (GDPR): The primary EU regulation governing personal data processing, setting requirements for transparency, lawful basis, and data subject rights (Regulation (EU) 2016/679)
Danish Data Protection Act (Databeskyttelsesloven): Danish law implementing GDPR, providing specific national requirements for data processing and additional safeguards (Act No. 502 of 23 May 2018)
Danish Executive Order on Data Protection (Databeskyttelsesbekendtgørelsen): Supplementary regulations detailing specific requirements for data processing in Denmark
Danish Marketing Practices Act (Markedsføringsloven): Relevant if the data processing involves any marketing activities or commercial communications
Danish Electronic Communications Act (Lov om elektroniske kommunikationsnet og -tjenester): Applicable if processing involves electronic communications data or requirements for electronic communications
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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