We process information about our partners’ employees so that our collaboration can function effectively and we can carry out our work.
In addition to being subject to general data protection legislation, LD Pensions is also subject to a number of further requirements that have implications for the processing of personal data. These include, amongst other things:
- The Public Procurement Act, which requires LD Pensions to select partners through a competitive tendering process.
- The Public Administration Act, which requires LD Pensions to be able to account for its administration.
- Archival obligations for public authorities, which mean that LD Pensions must deposit a number of records with the National Archives.
- The EU Market Abuse Regulation, which includes a prohibition on the disclosure of inside information concerning listed companies and securities.
- A general requirement for confidentiality regarding investment partnerships, under which LD Pensions undertakes to keep information about other financial stakeholders confidential.
Information, purposes and legal basis for processing
The information that LD Pensions processes regarding employees of its Partners consists of so-called general information, such as name, email address, telephone number, job title, place of employment, employment history, CV and skills. There may also be information regarding natural persons’ personal financial relationships to an investment matter.
We receive information either from the individual concerned or from the company they work for.
For example, we receive and process information about selected employees from companies submitting tenders for a contract we have put out to tender, to the extent necessary for LD Pensions to assess whether the tenderer meets the requirements set out in the tender conditions. In addition, we receive and process contact details for the contact person at the various tenderers. The information is processed in accordance with Article 6(1)(e) of the General Data Protection Regulation, as it is necessary for the performance of the tasks entrusted to us by virtue of our role as a fund established under The Cost-of-Living Allowance Fund Act.
Treatment activities
We process personal data relating to employees of our Partners in the following contexts:
- When assessing tenders received and selecting Partners in connection with tenders, as well as in correspondence with contact persons at these Partners.
- Contact persons and decision-makers in ongoing collaborations.
- Contact persons and decision-makers in investment matters, etc., where LD Pensions is required to exercise its shareholder rights and protect its investment.
- Discussion partners in professional networks relevant to LD Pensions.
Contact details may be disclosed to third parties who are involved in the collaboration or act as advisers to LD Pensions, such as law firms, auditors or consultants.
Confidential personal data may be disclosed to LD Pensions’ advisers or consultants, provided that they are bound by a duty of confidentiality. This will apply, amongst other things, to personal data provided to LD Pensions as part of work on an investment case. Furthermore, personal data provided to LD Pensions as part of the tendering process, for example in relation to contracts put out to tender, may be included in the evaluation process for the tender submitted.
Retention period
We retain personal data relating to selected employees and the contact person at the tenderer that wins the relevant tender, for up to 3 years after the contract expires, or for longer if required by law or necessary in relation to potential or current claims between LD Pensions and the tenderer.
We retain personal data relating to selected employees and the contact person at tenderers who do not win the tender in question for up to 6 months after the tenderer has been informed that they have not won the tender, cf. Section 7(2)(3) of the Executive Order on the Complaints Board for Public Procurement. The data may be retained for longer if required by law or necessary in connection with potential or current claims between LD Pensions and the tenderer.
Your rights
You have the right to request access to, and the rectification and erasure of, your personal data. You also have the right to request restriction of processing, to object to processing, and to request data portability. The exercise of these rights may be subject to certain conditions or restrictions, depending on the circumstances surrounding the processing in question and/or your specific situation.
If you wish to exercise the rights set out above, or if you have any questions regarding our processing of personal data, please contact us or our Data Protection Officer here:
