Personal Data Policy

Finansforbundet is the data controller for the processing of the personal data we have about you.

Here is our contact information:

Finansforbundet
Snorresgade 15
2300 København S

Tel. 32 96 46 00

Gdpr@finansforbundet.dk (all about GDPR)
post@finansforbundet.dk (all other inquiries)
CVR 15320613

Finansforbundet’s responsibility for data includes the following CVR numbers:

If you have any questions about how Finansforbundet processes your personal data, please contact Finansforbundet’s data controller, Mette Hjøllund Schousboe.

You can also contact:

• Via email: GDPR@finansforbundet.dk
• Via phone: 32 96 46 00
• Via regular mail: Finansforbundet, Applebys Plads 5, Postboks 1960, 1411 København K, att. Mette Hjøllund Schousboe

We process personal data about you as part of our activities as a trade union

For example, we process your data in these situations:

• When you join Finansforbundet and for the subsequent payment of the membership fee.
  
  
• Administration of your membership.
  
  
• When you contact us physically, via phone, via social media or via email to get advice and guidance on, e.g. terms of employment, job satisfaction, work environment, social legislation or issues relating to collective agreements etc.
  
  
• When you use Finansforbundet.dk or our other self-service solutions.
  
  
• When you participate in career interviews, educational counselling and personal development sessions.
  
  
• When you participate in skills development projects.
  
  
• When you participate in professional networking activities and member surveys.
  
  
• When you register for and participate in courses, conferences, webinars, general meetings or similar events.
  
  
• In connection with campaigns and organisation projects.
  
  
• When we enter into, renew and enforce collective agreements.
  
  
• When we prepare salary statistics.
  
  
• If we have to file a case for you.
  
  
• If you want to end your membership with Finansforbundet and we contact you about possible re-enrolment.
  
  
• If you contact Finansforbundet about one of our member cases, projects or events.
  
  

We also use your personal data to give you personalised communication and for marketing of membership offers. We use letters, email, text messages and social media for this.

Finansforbundet often processes your personal data as part of our legitimate activities as a trade union. The legal basis for processing the information is the General Data Protection Regulation, Article 9(2)(d) (trade union authorisation) combined with Article 6(1)(f) (legitimate interest).

The legal basis for processing the personal data may be:

• GDPR, Article 9(2)(d) (trade union authorisation)
• GDPR, Article 9(2)(a) (consent)
• GDPR, Article 9(2)(b) (employment law obligations and specific rights, e.g. in the Danish Salaried Employees Act or collective agreement)
• GDPR, Article 9(2)(e) (published information on social media such as LinkedIn and Facebook)
• GDPR, Article 9(2)(f) (legal requirements)
• GDPR, Article 9(2)(j) (statistics and scientific purposes)

As well as one of the following authorisations:

• GDPR, Article 6(1)(a) (consent)
• GDPR, Article 6(1)(b) (fulfilment of contract)
• GDPR, Article 6(1)(c) (legal obligation)
• GDPR, Article 6(1)(d) (vital interest)
• GDPR, Article 6(1)(f) (legal interest)
• GDPR, Article 10 (criminal convictions)
• Danish Data Protection Act § 8-3 (criminal convictions)
• Danish Data Protection Act § 10 (statistics and scientific purposes)
• Danish Data Protection Act § 11 (personal identification number)
• Danish Data Protection Act § 12 (information in employment relationships)

Data on members and former members

We process information about you as part of your current or previous membership with Finansforbundet. Being a member of a trade union is a ‘special category of personal data’ as understood in the GDPR (Article 9).

We process this information about you:

• Membership with Finansforbundet
• ID number
• Ba, including your name and job title, private address, private phone numbers, email address, account number and salary information and statistics
• Your educational background
• Your workplaces
• When you have been in contact with Finansforbundet electronically or via phone
• Which electronic newsletters you have received
• Which electronic letters you have received from Finansforbundet, as well as the newsletters you have read
• Number of insurance policies you have taken out via Finansforbundet’s agreement with Tryg on member insurances
• Which Finansforbundet courses and events you have been registered for, unregistered from and participated in
• Member surveys
• Information about diet (e.g. whether there are any foods you do not eat in connection with catering for courses)
• Any positions of trust and election date (union representative, working environment representative, employee board member, representative for the National Congress and Assembly of Representatives etc.).
• Information on testing (if you have participated in a course or development process in which tests were used)
• Your CV (if you have participated in a personal career advice interview or applied for a vacant position in Finansforbundet)

In special cases, will process additional information about you. For example, this could be in connection with you having gotten professional or legal assistance from Finansforbundet:

• Information on health conditions (e.g. in professional cases where it is relevant, if you are handicapped, are in subsidised employment, or where illness affects your employment relationship or right to other benefits)
• Information on social conditions
• Information on political or religious affiliation or race, ethnicity or sexual orientation
• Information on criminal matters

Information on others who have been in contact with Finansforbundet

We process the information about you that you yourself have given us or published. We only collect the information that is relevant and necessary to fulfil the purpose of the processing.

We also process information about you in connection with our organisational activities.

We may also process information about you if it is part of a member’s professional case. This could be as a colleague, manager, customer or something similar. In these situations, we often will not have your contact information, as the information we receive about you may be random information from members as part of a professional case.

Some information is necessary for us to establish you as a member and help you on an ongoing basis when you need it. If you do not want to share this information, we will unfortunately not be able to provide you with optimal help and ensure that you get the services you are entitled to – and ultimately we may not be able to establish you as a member at all.

It is of course entirely up to you what information you want to share, but you should know what it means for your membership:

• Without basic identification information such as name, address and social security number, we cannot create your membership and receive payment, which unfortunately means we will not be able to offer you membership.
• If we do not have specific information about a case, we cannot provide you with optimal advice and assistance in labour law cases. For example, this applies to information about the reason for termination, unemployment, your employment history and other information relevant to the case. Unfortunately, this means that we cannot provide you with optimal help and ensure that you receive the services you are entitled to.

It is entirely up to you if you want to use our offers and make use of our advice and assistance in legal cases etc. If you want our advice in a case, we will need information about the reason for termination, unemployment, your employment history and other information relevant to the case. If we do not have this information, we will unfortunately not be able to provide you with optimal help and ensure that you get the services you are entitled to.

Finansforbundet does not normally record phone conversations. If we believe it is necessary to record a phone conversation in a specific situation, we will inform you before the conversation.

All our employees are bound by confidentiality.

We only disclose or transfer your personal data when it is necessary or appropriate for you. This may involve:

• Public authorities
• Doctors
• Elected representatives
• FH and other trade unions
• Unemployment insurance funds
• Banking, insurance and pension companies
• Hotels and conference venues
• Educational institutions and external instructors
• Courts and judicial bodies
• Employers and employers’ organisations
• Advisers, such as attorneys, auditors, consulting companies etc. if this is necessary to assist you
• Data processors, i.e. external private companies or public authorities/institutions that only process information on behalf of and in accordance with instructions from Finansforbundet.

As a general rule, Finansforbundet does not transfer your personal data to unsecure third countries.

When you use Finansforbundet’s services, your personal data may in some cases be transferred to countries outside the EU/EEA. For example, this may be in situations where we use data processors and these use suppliers established outside the EU/EEA. In such cases, it will be clear in our agreement with the supplier that they must as a minimum meet with the same security required within the EU/EEA.

We primarily collect the information directly from you. However, we may obtain or receive information directly from third parties. We only collect the information that is relevant and necessary.

This involves information from:

• Unemployment insurance funds
• Employers
• Occupational medicine clinics
• Retslægerådet (a Danish public institution)
• Arbejdsmarkedets Erhvervssikring (“Labour Market Insurance”, AES)
• The Danish National Social Appeals Board
• Cpr-registret (Danish Central Person Registry)
• Your colleagues
• Your relatives
• Your insurance company
• Your pension company
• Holiday account
• FH or other trade union
• Job centres/Municipalities
• Doctors or other practitioners
• Counterparties in cases (Employers, attorneys, employer organisations etc.)
• Police and courts
• SKAT (Danish tax agency)
• STAR (Danish National Labour Market Authority)
• Delegates (including local union, professional staff associations and insurer associations)
• Udbetaling Danmark (a Danish government agency)
• Public authorities
• Members of Finansforbundet (e.g. when registering for events that are also open to persons who are not members of Finansforbundet or for campaigns and organisational activities)

When you visit www.finansforbundet.dk, we collect personal data about you when you:

• Subscribe to a newsletter
• Register for an event or competition
• Use a tool on Finansforbundet.dk, such as salary calculator and parental benefits calculator
• Contact us
• Consent to the use of cookies

We only collect the information we need to process your request or provide a service. We will normally only ask for additional information if we need it to provide you with the best possible response to your inquiry or if we want to offer you membership. When you consent to the processing of your personal data, we only process the personal data you have specifically consented to.

We cooperate with partners in social media, advertising and analysis to optimise Finansforbundet’s marketing on social media and other websites.

You can read more about Finansforbundet’s use of cookies here: Finansforbundet’s privacy and cookie policy

Finansforbundet’s unemployment insurance fund – part of FTFa, is a collaboration between FTFa and Finansforbundet. FTFa has stationed advisors in Finansforbundet’s secretariat who can advise on unemployment insurance matters.

When you join Finansforbundet, you can also join FTFa via our joint registration form. If you use the form and opt for membership in FTFa, you provide the necessary information directly to FTFa yourself.

FTFa is an independent data controller for the information you provide them. You can read more in FTFa personal data policy

In some situations, there may be a need for Finansforbundet to disclose information about you when you seek advice from Finansforbundet that involves advice on unemployment insurance matters. If it is necessary to disclose information to FTFa (stationed FTFa advisors), you will be asked to give your consent beforehand.

Finansforbundet uses social media to create visibility in society, and maintain dialogue and relations with current and potential members.

We share responsibility for data with a number of social media services with regard to Finansforbundet’s profile pages and when we target the material we send out.

You will find information about Finansforbundet’s use of these media services and processing of personal data here.

Finansforbundet stores your information for as long as is necessary for the intended purposes. This means that we save information for the period for which we may be presented with a claim, are legally required to or have another legitimate purpose for the storage.

If you have been a party to a case that we have brought on your behalf, we store the information for up to six years from the end of the case. In specific cases, it may be necessary to store the information for longer than six years.

If you end your membership, we store your personal data for up to two years afterwards unless you have been a party to a case that has not yet expired/been deleted. In those cases, we store your personal data until the case expires and is deleted.

Information on meetings of the National Congress, board meeting minutes and cases regarding interpretation of law and collective agreements are generally not deleted from the organisation’s memory bank in relevant cases and documentation of Finansforbundet’s history.

Finansforbundet does not make decisions based solely on automatic processing of personal data, including profiling in connection with Finansforbundet’s trade union activities.

As a general rule, Finansforbundet does not use consent as a basis for processing your personal data. In some situations, however, we still obtain consent from you to process or disclose personal data, and in those cases, you always have the right to withdraw your consent. There are several ways to do this:

• Write to the email address you were given when you gave your consent
• Unsubscribe directly from the email sent to you
• Withdraw consent on ‘Mit forbund’ (‘My association’) (e-Boks, membership fee via salary deduction and marketing from Finansforbundet’s partners) or
• Contact us by phone at 32 96 46 00 or write to us at post@finansforbundet.dk

If you choose to withdraw your consent, it will not apply retroactively. This means that our processing of your personal data will be legal until the time when you withdraw your consent.

Finansforbundet stores your personal data securely and confidentially. We have both technical and organisational security measures to protect your information from accidental or unlawful destruction, loss or deterioration, as well as it being improperly shared, misused or otherwise processed in violation of the law.

When we disclose your information, we always use secure communication.

You have the following rights when we process your personal data:

The right to view information (right of access)

• You have the right to access the information we have registered as well as a range of additional information.

Right to rectification (correction)

• You have the right to have incorrect information about yourself corrected.

Right to erasure

• In special cases, you have the right to have information about deleted before the time our normal deletion generally occurs.

Right to restrict processing

• In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to restrict processing, we may in the future only process your data with your consent – except for storage – or for the purpose of determining, asserting or defending legal claims or to protect a person or important public interests.

Right to object

• In certain cases, you have the right to object to Finansforbundet’s processing of your personal data. You can also object to the processing of your personal data for direct marketing.

Right to transfer data (data portability)

• In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have this data transferred from one data controller to another.

You can read more about your rights in the Danish Data Protection Agency’s guidelines on registered rights, available at www.datatilsynet.dk.
If you want to use one or more of your rights, contact Finansforbundet. You can email GDPR@finansforbundet.dk

You have the right to complain to the Danish Data Protection Agency if you disagree with the way we process your personal data. You are also welcome to contact us first, so that we can investigate whether we can accommodate you with regard to what you disagree with.

You will find the Danish Data Protection Agency’s contact information at www.datatilsynet.dk.

This personal data policy will be updated and amended at regular intervals, when necessary as a result of changes in law and practice in data protection, or when our use of new technology options makes it necessary. We therefore recommend that you keep updated on our website.

We will notify our members directly if there are major changes.

The personal data policy was last changed on 22/11/2022.