The Danish Shipowners’ Accident Insurance Association (UFDS) is the data controller responsible for the personal data that we handle.
Our personal data policy describes how we process data about you, where we obtain the data and which data we process. The personal data policy also describes your rights in relation to the data about you that we handle.
Under the Danish Financial Business Act, UFDS is subject to a duty of confidentiality. Accordingly, we pass on your data only if we have a legal basis to do so. The Danish Workers’ Compensation Act or the personal data regulations may provide us with this legal basis. If we do not have a legal basis for passing on data, we will ask for your consent to pass on the data.
Personal data policy
UFDS collects, registers and passes on your personal data in accordance with the Danish Workers’ Compensation Act (Consolidation Act No. 216 of 27 February 2017) with the related executive orders.
All your personal data will be treated confidentially and in accordance with the Danish Data Protection Act (Act No. 502 of 23 May 2018).
When processing an accident claim we register the data that we are obliged to under the Workers’ Compensation Act as well as the data required to process the claim and calculate any compensation under article 6(1)(b) of the General Data Protection Regulation (about performance of a contract), article 9(2)(f) (about legal claims) and article 6(1)(f) (about legitimate interests).
1. Which data do we register and what do we use them for?
When we receive an industrial injury claim, we register your name, address, civil registration number, information about the injury concerned, your job title, income data, description of the incident, account details, if applicable, and information about your health.
UFDS registers the collected data for administration purposes as well as to enable us to advise you and process your case, including whether it is to be processed by Labour Market Insurance and whether we can cover the processing costs.
2. Data collection
Once we have registered your claim, as a rule, we send you a questionnaire for you to personally fill in with a range of details.
If we need further information, for example, from doctors, dentists or others, we will ask for your authorisation to obtain this information before doing so. UFDS either forwards this information to Labour Market Insurance, which will make a decision about your claim, or uses it to decide whether you are entitled to cover under the Workers’ Compensation Act.
We only ask doctors, dentists and other parties for the information we specifically require to process your case.
UFDS registers information from the Civil Registration System (CPR) to keep its address records up to date.
3. Storage and erasure
UFDS stores identifiable personal data about you for as long as there is a case-related reason to do so.
This means we store data for the period of time in which UFDS may be faced with a claim that imposes an obligation on UFDS, is obliged to store the data in accordance with legislation (eg, the Danish Act on Bookkeeping and financial supervision legislation) or has another objective purpose for storing the data.
As a rule, we store data according to the time limits of the Danish Limitation Act, namely, 10 years from the date of damage in the case of property damage and 30 years from the date of injury in the case of personal injury.
The data about you are then erased.
4. Passing on information about you
In principle, UFDS does not pass on personal data, as, under the Financial Business Act, we are subject to a duty of confidentiality. During our assessment of the claim, UFDS may use professional consultants and pass on your health information in that connection.
UFDS has out-sourced the processing of claims to Sedgwick Leif Hansen A/S, whereas all information of claims, including of personal data, is passed on to Sedgwick Leif Hansen A/S. However it is still the resposibility of UFDS to manage your personal data in a satisfactory manner, which complies witth he current law.
Under the Workers’ Compensation Act and the related executive orders, UFDS/Sedgwick Leif Hansen A/S may be obliged to pass on personal data to Labour Market Insurance, the Social Board of Appeal, and the Danish Tax Agency.
In the event of fraud, UFDS/Sedgwick Leif Hansen A/S will pass on personal data to the police in connection with the reporting of the case.
5. E-mail communication
We encrypt any e-mails we send to you that contain a civil registration number or sensitive personal data.
Our e-mail gives you the possibility of sending encrypted e-mail to UFDS.
If you send e-mails in any other way, you are personally responsible for encryption and confidentiality.
6. Our website
7. Personal data breach
In the event of a personal data breach at UFDS or our data processors, UFDS is required to report the breach to the Danish Data Protection Agency.
Our data processors work according to our instructions and are subject to our requirements regarding organisational, technical and security measures.
If we discover a personal data breach, under the legislation we are required to report the breach to the Data Protection Agency within 72 hours.
If the breach additionally poses a high risk to your rights and freedoms, we will also inform you directly by e-mail and letter.
8. Data transfer to third countries
If you live in Denmark, your data will not be transferred to other countries, either inside or outside the EU.
If you do not live in Denmark, UFDS may, when obtaining a specialist doctor’s opinion in connection with the processing by the Danish authorities, transfer copies of documents from Labour Market Insurance to a doctor in your home country/the country you live in.
As such, the transfer is made to ensure your claim against UFDS can be assessed on a sound basis and in accordance with the Workers’ Compensation Act.
9. Your personal data rights
You can read more about your rights in the Data Protection Agency’s guidance about the rights of data subjects on www.datatilsynet.dk (available in Danish only).
If you have given consent for us to collect data from third parties, this will be available in writing.
You can withdraw your consent at any time – either in writing, by letter or e-mail, or by phone.
If you withdraw your consent, please let us know if you want us to drop the claim or if you want it processed by Labour Market Insurance.
You can request a copy of the data that UFDS has registered about you.
You are entitled to have inaccurate personal data about yourself corrected or supplemented with additional data, if this makes your personal data more complete.
We draw your attention to the fact that if changes are made to already submitted statements about a course of events or the extent of an injury, we will ask Labour Market Insurance to make a decision about which statement will be accorded weight.
In certain cases you can have the data UFDS holds about you erased before the time for our own general erasure occurs.
Restriction of processing
You can inform us that you only want your data subjected to restricted processing and only want them processed with your consent for the purpose of establishing a legal claim or for protecting a third party.
If you do not want us to process your data, you can ask us to drop the claim.
10. Changes to any incorrect personal data and access to copies of personal data
You can always find out what personal data UFDS has registered about you, and which personal data we pass on.
You are also entitled to have any incorrect personal data modified or erased. You can also always find out what your consent covers.
You can direct your inquiries to:
The Danish Shipowners’ Accident Insurance Association (UFDS)
Amaliegade 33 B, 2nd floor
1256 Copenhagen K
Or send an e-mail to:
11. Complaints about UFDS’ data processing
If you are dissatisfied with UFDS’ processing of your data, you can file a complaint with:
The Danish Data Protection Agency
Borgergade 28, 5th floor
1300 Copenhagen K
12. Data Protection Officer
If you have any questions or comments as to how we handle your personal information, please contact our data protection officer:
Phone: +45 2936 2465