Business partners
We process data relating to our business partners’ employees in order to facilitate our collaboration and enable us to carry out our work.
As well as being governed by general data protection legislation, LD Pensions is also subject to various additional requirements relating to the processing of personal data, including:
- the Danish Public Procurement Act, which requires LD Pensions to select its business partners through competitive procurement;
- the Danish Public Administration Act, which requires LD Pensions to be able to account for its administration;
- archiving obligations applicable to public authorities, under which LD Pensions is required to deposit various records with the Danish National Archives;
- the EU Market Abuse Regulation, which prohibits the disclosure of inside information concerning listed companies and securities;
- a general non-disclosure requirement applicable to investment cooperation, under which LD Pensions is obliged not to disclose information about other financial stakeholders.
Information, purpose and legal basis for processing
The data processed by LD Pensions relating to the employees of business partners consists of so-called ordinary data, such as name, email address, telephone number, job title, place of work, employer references, CV and qualifications. The data may also include information about a natural person’s personal financial interests in relation to an investment matter.
We receive the data from the person concerned or from the company that employs that person.
By way of example, we receive and process data on certain employees from companies tendering for a contract with us, insofar as such data are necessary for LD Pensions to assess whether the tenderer meets the requirements set out in the tender specifications. In addition, we receive and process contact details for the contacts of the various tenderers. The personal data is processed in accordance with Article 6(1)(e) of the General Data Protection Regulation, as the processing is necessary for the performance of tasks imposed on us by virtue of our work as a fund established under and operating in accordance with Danish law.
Processing activities
We process personal data relating to the employees of our business partners in the following situations:
- when assessing tenders received and selecting business partners in connection with tender procedures and correspondence with the business partners’ contacts;
- contacts and decision-makers in ongoing business relationships;
- contacts and decision-makers in investment matters, etc., in which LD Pensions must exercise its shareholder rights and protect its investments;
- in professional discussions with partners in professional networks relevant to LD Pensions.
Contact details may be disclosed to third parties involved in a business relationship with LD Pensions or acting as advisers to LD Pensions, such as law firms, accountants or consultants.
Personal data may be disclosed to LD Pensions’ advisers or consultants, provided that they are bound by a non-disclosure obligation. Such data includes personal data provided to LD Pensions for the purposes of an investment matter. Furthermore, personal data provided to LD Pensions in connection with, for example, a tender for a contract may be included in the process of evaluating the tender submitted.
Storage period
We store personal data relating to certain employees and the contact details of the successful tenderer for a period of up to three years after the contract has expired, or for longer if required by law or for the purpose of potential or actual claims between LD Pensions and the tenderer.
We store personal data relating to certain employees and the contacts of unsuccessful bidders for a period of up to six months after the bidders have been informed that they did not win the contract; see section 7(2)(iii) of the Danish Act on the Complaints Board for Public Procurement. The data may be stored for a longer period if required by statutory law or for the purpose of potential or actual claims between LD Pensions and the bidders.
Your rights
You have the right to access, rectify and erase your personal data. You also have the right to request restriction of processing, the right to object to processing, and the right to data portability. The exercise of these rights may be subject to certain conditions or restrictions, depending on the circumstances surrounding the relevant processing and/or your particular situation.
If you wish to exercise the above rights or if you have any questions regarding our processing of personal data, you can contact us or our data protection officer here:
Contact
If you would like information on how to contact either LD Pensions or our data protection officer:
