We process data about the employees of our business partners in order to facilitate the cooperation and enable us to perform our work.
In addition to being governed by general data protection legislation, LD Pensions is also subject to various additional requirements affecting the processing of personal data, including:
- the Danish Public Procurement Act, which imposes an obligation on LD Pensions to select its business partners through competitive procurement
- the Danish Public Administration Act, which imposes an obligation on LD Pensions to be able to account for its administration
- archive obligations applicable to public authorities, according to which LD Pensions is required to file various records with the Danish National Archives
- the EU Market Abuse Regulation, which contains a prohibition against disclosure of insider information about listed companies and securities
- a general non-disclosure requirement applicable to investment cooperation, according to which LD Pensions not is obliged to disclose information about other financial stakeholders.
Information, purpose and processing basis
The data processed by LD Pensions about the employees of business partners are so-called ordinary data such as name, email address, telephone number, title, place of work, employer references, CV and qualifications. The data may also include information about a natural person's personal financial relations to an investment matter.
We receive the data from the relevant person or from the company employing the person.
E.g. we receive and process the necessary data on certain employees from companies bidding for a contract with LD Pensions in order for LD Pensions to be able to assess, whether the bidder meets the requirements of the tender specifications. In addition, we receive and process contact data on the contacts of the various bidders. The personal data is processed pursuant to Article 6(1)(e) of the General Data Protection Regulation, because the processing is necessary for the performance of tasks imposed on us due to our work as a fund established under and operating according to Danish law.
We process personal data about the employees of our business partners in the following situations:
- when assessing bids received and selecting business partners in connection with tender procedures and correspondence with the contacts of the business partners;
- contacts and decision makers in relation to ongoing business relationships;
- contacts and decision makers in relation to investment matters, etc. in which LD Pensions must exercise its shareholder rights and protect its investments;
- in professional dialogues with partners in professional networks of relevance to LD Pensions.
Contact data may be disclosed to third parties participating in a business relationship or working as advisors to LD Pensions, e.g. law firms, accountants or consultants.
Personal data may be disclosed to LD Pensions' advisors or consultants provided that they are bound by a non-disclosure obligation. Such data include personal data passed on to LD Pensions for purposes of an investment matter. Furthermore, personal data passed on to LD Pensions in connection with e.g. a bid for a contract may be included in the process of evaluating the submitted bid.
We store personal data on certain employees and the contact of the bidder winning the relevant tender for a period of up to three years after expiry of the contract, or longer if required by statutory law or for the purpose of potential or actual claims between LD Pensions and the bidder.
We store personal data on certain employees and the contacts of the losing 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.
You have a right of access to, rectification of and erasure of your personal data. You also have a right to request restriction of processing, a right to object to processing, and a right to data portability. The exercise of those 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 questions to our processing of personal data, you can contact us or our data protection officer here:
If you want to contact LD Pensions:
+45 33 36 89 00
Dirch Passers Allé 27, 2nd floor
If you want to contact our data protection officer: