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Privacy Policy for Members

Here you can find an overview of the types of information we process about you if you are a member of The Cost-of-Living Allowance Fund. We also provide information about your rights.

If you have accrued holiday allowance funds with The Holiday Allowance Fund, you can find out more about how we process your personal data at borger.dk.

Processing of your personal data as a member using cost-of-living allowance funds

We process your personal data in order to fulfil our obligations regarding the management of your accrued cost-of-living allowance funds and the payment of those funds to you. The legal basis for the data processing is therefore the relevant legislation, primarily the LD Act. 

Groups of people

LD Pensions’ processing of personal data relating to long-term members covers the following groups:

  1. Members with savings in the Cost-of-Living Allowance Fund.

  2. Former members who have had their savings paid out or transferred to a pension provider.

  3. Former members who have lost their entitlement to the savings because the funds have reverted to the fund. 

  4. Persons acting on behalf of members. These may include estate administrators, heirs and relatives of members or former members in groups 1, 2 and 3. They may also include persons who have been granted read or write access to members’ digital mail.
    Individuals in Group 4 are involved in the processing of data relating to Groups 1, 2 and 3 where this is necessary to safeguard their rights.

Categories of personal data

The information about you and your cost-of-living allowance funds was transferred to LD Pensions in 1980 from ATP, which had collected and recorded this information in accordance with the legislation on the freezing of cost-of-living allowance funds. LD Pensions updates your details using information from the CPR register. 

The processing of data covers the following categories of personal data relating to members and former members:

  • Personal ID (name, CPR number, LD customer number)
  • CPR register details (address, date of death, date of departure)
  • Contract information (residential address, exemptions from official digital mail and, where applicable, email address/telephone number)
  • LD Account details (amount, portfolio selection, tax status)
  • Payouts details (reason, amount, date, NemKonto/bank account)
  • Information on pension transfers (amount, date, receiving pension institution)
  • Correspondence between LD Pensions and members or former members
  • Correspondence between LD Pensions and persons acting on behalf of members
  • Correspondence between LD Pensions and authorised authorities
  • Entries in the record-keeping system (telephone notes, emails, correspondence, digital messages)
  • Records of orders placed via self-service solutions
Data processing relating to individuals acting on behalf of members (Group 4) covers the following information:
  • Name and, if applicable, guardian (name and contact details)
  • CPR number, if applicable
  • Appointment or declaration of power of attorney 
  • Correspondence between LD Pensions and persons acting on behalf of members
  • Notes from conversations with individuals acting on behalf of members

Special categories of information

LD Pensions does not process special categories of personal data under Article 9 of the EU Regulation concerning illness, etc., or under Section 8 of the Data Protection Act concerning criminal offences. LD Pensions processes information on whether the conditions for payouts have been met in cases where early retirement pension or life-threatening illness has been recognised. Members may provide information to LD Pensions regarding illness and health in connection with an application for payouts, even though such information is not a requirement. 

Disclosure of personal data in the members’ area

Data processing may involve the disclosure of personal data to the following categories of recipients.

Categories of recipients
    • The Danish Tax Agency (taxes, early retirement scheme)
    • Probate courts
    • National wealth statistics
    • Local authorities and social welfare authorities, provided that there is documentation showing that the authority in question has a legal right to the information
    • Public digital mail (eBoks)
    • MitID
    • NemKonto
    • The State Payment Bank
    • LD Pensions’ paying bank (Danske Bank / Statens Udbetalingsbank)
    • Banks for registered parties
    • Banks for estate administrators
    • Banks for pension institutions
    • Pension institutions requesting information and the transfer of funds
    • Persons acting on behalf of members or former members. For example, estate administrators, relatives, heirs and guardians.
    • Researcher database (third-party analyses for the data controller)

No personal data is transferred to third countries or international organisations.

Deletion of personal data

LD Pensions deletes personal data five years after the payouts have been made. This applies regardless of whether the payouts were made to the member, to the estate following the member’s death, or by transfer to the member’s pension provider. 

For the few accounts where the member’s savings revert to the fund, we delete the data five years after the reversion. 

If, more than five years after the payouts, there has been any reporting to the authorities, correspondence or other actions relating to you and your funds, the deletion process is postponed until five years after the last such action.  

Upon deletion, we remove all correspondence and information regarding the use of self-service, etc. After deletion, we retain only a few key pieces of information. This includes your CPR number, the payment date, and whether the payouts were made to the member, the member’s pension institution, or whether the funds have reverted to the fund. We retain this limited key information in order to be able to respond to enquiries regarding the savings from former members or their next of kin. 

Questions regarding the processing of your personal data

You can contact LD Pensions if you have any questions regarding our processing of your personal data. These may include questions about:

  • what information is being processed 
  • correcting your data
  • requests for the erasure of data
  • objecting to our processing of your data.

As a member of The Cost-of-Living Allowance Fund, we suggest that you contact LD Member Service:

Contact

Please contact us if you have any questions.

Go to contact

You can also contact LD Pensions’ data protection officer. The role of data protection officer is carried out by Compliance Team Aps, which can be contacted by email at ld@complianceteam.dk or via its website.

Contact the Compliance Team

Once the Data Protection Officer has obtained the relevant information from LD Pensions, they will respond to your enquiry.