How Lønmodtagernes Feriemidler processes your personal data

Here you can learn about what data Lønmodtagernes Feriemidler processes, how the data is processed and what rights you have when we process cases and inquiries concerning:

• Reporting of outstanding holiday funds
• Account statements and account indexation
• Payment of holiday funds
• Repayment of holiday funds that the recipient was not entitled to
• Registration of guardianships or powers of attorney

Lønmodtagernes Feriemidler is responsible for the processing of the personal data that we have about you.

The data controller for Lønmodtagernes Feriemidler is LD Fonde, central business registration number 61552812.

We process your personal data for the following purposes:

• To ensure that you get your outstanding holiday funds registered as they are reported by your employer(s).
• That the amounts are adjusted during the period the holiday funds are placed with the fund.
• That you get paid your holiday funds automatically or when applying for them.
• That you pay back holiday funds that you received without being entitled to.
• To verify information in connection with reporting, application, payment or when contacting the fund.
• To train our employees and improve the customer experience (if you call us and accept that we can record the conversation).
• To test our systems in connection with development, optimisation of operations and, if relevant, fixing errors.

We only collect information about you that we need to process your case.  

We collect the following types of personal data about you:

Common personal data

• We receive civil registration numbers and other basic data from the Danish Civil Register.
• We receive information about income, etc. from the Danish Tax Agency.
• We receive information about account numbers/NemKonto from the Agency for Digital Government.
• We receive information about your employment conditions and accrued holiday funds from your employer.
• From you we receive information about your TIN (tax identification number)

Sensitive personal data

• From yourself we can retrieve health information that has an impact on dispensation from applications sent in too late about an early payment or for benefits that you have been granted in connection with the application for a payment in the event of early retirement.

We process your personal data on the basis of the Act concerning the amendment of the Danish Act on the Processing and Administration of Outstanding Holiday Pay (Lov om forvaltning og administration af tilgodehavende feriemidler), Act no. 58 of 30/01/2018 with amendments.  

We can obtain and coordinate data for case processing and for checking payments, etc. This can be done with the help of Udbetaling Danmark – Public Benefits Administration on the basis of special provisions in the Danish Udbetaling Danmark Act and established guidelines, including those for erasure of data.

We can pass on information about you to other public authorities such as the Danish Tax Agency, Lønmodtagernes Garantifond, the Danish Debt Collection Agency, Udbetaling Danmark or financial institutions which are legally entitled to receive this information or to parties that Lønmodtagernes Feriemidler collaborates with. In special cases, we will pass on your personal data to countries outside of the EU/EEA, though only if your employer is domiciled outside of the EU/EEA.

We store your information during the processing of your case and delete them at the earliest three years after the holiday funds have been disbursed or, if relevant, repaid and the holiday funds from your employer have been fully contributed to the fund, Lønmodtagernes Garantifond or the Danish Debt Collection Agency. The information is stored after the case has been closed due to rules in the Danish Limitation Act, the Danish Bookkeeping Act and the Danish Archiving Act.

If you have consented to Lønmodtagernes Garantifond recording a conversation, we will delete this conversation after two months. You can always have the conversation deleted earlier by contacting Lønmodtagernes Garantifond.

We can make decisions that are solely based on automated processing. The automated decisions are made by us retrieving information from public registries that are then compared by a computer programme with information in your case and this together determines whether you are entitled to a payment, if you have received more than you were entitled to or if your case should be transferred to the Danish Debt Collection Agency or be subject to a control.

You can receive a copy of the data we process about you (insight).

You can complain about us processing your personal data (objection).

You may also request:

• to have your personal data rectified or erased
• to have the data sent to you or someone else (data portability)
• that we suspend the processing of your data.

And finally, you can object to us making automated decisions.

If you ask to have your personal data erased, we may not be able to comply with your request.

There may be conditions or limitations to the rights mentioned above. It is therefore not guaranteed that, for example, you have the right to have your personal data deleted in a specific context – this will depend on the specific circumstances in connection with the data processing. Among other things, this may be due to your personal data being used in a case involving a payment to a third party or for legal compliance reasons.

Do you have questions about your case?

If you have questions concerning your case, please contact Lønmodtagernes Feriemidler.

• Contact Lønmodtagernes Feriemidler

Do you have any questions about your personal data? 

If you have any questions concerning our processing of your personal data or if you want to exercise your rights to, for example, get access to or erase your personal data, you can contact Lønmodtagernes Feriemidler.

• Contact Lønmodtagernes Feriemidler

 If you write us, please write “Personal data” in the subject line.

Are you dissatisfied with the processing of your personal data?

You can contact the Data Protection Officer, if you think

• that you have not received a satisfactory response to your request for access to your personal data
• that Lønmodtagernes Feriemidler has violated your rights.

LD Fonde’s data protection officer is Compliance Team ApS.

• Contact Data Protection Officer for LD Fonde (in Danish)

If you disagree with the way in which we process your personal data, you can also submit a complaint to the Danish Data Protection Agency.

Please note that the Danish Data Protection Agency is only a complaints body for Lønmodtagernes Feriemidler’s processing of your personal data – it does not handle complaints about the processing of your case itself.

If you disagree with how we have processed your case, you must contact Lønmodtagernes Feriemidler.

The data controller for Lønmodtagernes Feriemidler is LD Fonde, central business registration number 61552812.

Legal framework

• Article 6(1)(e) of the General Data Protection Regulation (common personal data)
• Article 9(2)(f)(1) of the General Data Protection Regulation (sensitive personal data)
• Article 45(1) of the General Data Protection Regulation (transfers to safe non-EU/EEA countries)
• Article 46(2)(a) of the General Data Protection Regulation (transfers to an unsafe non-EU/EEA country)
• Article 49(1)(e) of the General Data Protection Regulation (transfers take place for legal compliance reasons)
• Act concerning the amendment of the Danish Act on the Processing and Administration of Outstanding Holiday Pay (Lov om forvaltning og administration af tilgodehavende feriemidler), Act no. 58 of 30/01/2018 with amendments.

You can find the legal basis at

• Retsinformation (in Danish)
• EUR-Lex – European Union law

Acts

• The General Data Protection Regulation
• The Danish Data Protection Act
• Lov om forvaltning og administration af tilgodehavende feriemidler (in Danish)
• Seneste ændring af Lov om forvaltning og administration af tilgodehavende feriemidler vedrørende udbetalingsrunden i 2021(in Danish)
• Loven er ændret ved § 1 i Lov om ændring af lov om forvaltning og administration af tilgodehavende feriemidler vedrørende udbetalingsrunden i 2020 (in Danish)
• Change in the Act by § 3 in Lov om forvaltning og administration af tilgodehavende feriemidler (in Danish)
• Change in the Act by §22 in Lov om social pension mv. (in Danish)

Executive orders

• Bekendtgørelse om forvaltning og administration af tilgodehavende feriemidler (in Danish)
• Bekendtgørelse om førtidig udbetaling af feriemidler ved en ansøgningsrunde i 2021 (in Danish)
• Bekendtgørelse om førtidig udbetaling af feriemidler ved en ansøgningsrunde i 2020 (in Danish)
• Bekendtgørelse om fondsferiedage (in Danish)
• Bekendtgørelse om indeksering af tilgodehavende feriemidler hos arbejdsgivere i perioden 1. september 2020 til 31. maj 2021 (in Danish)