F­G­'­s­ ­P­r­i­v­a­c­y­ ­P­o­l­i­c­y

We process personal data at Forenede Gruppeliv (FG) and have therefore adopted this Privacy Policy which explains how we process and protect your personal data.

Responsibility for data

We process personal data on behalf of data controllers

FG is a data processor and provides and manages group life insurance on behalf of the companies listed below. These companies are data controllers for the personal data we process:

• Danica Pension, Livsforsikringsaktieselskab
• Norli Liv og Pension Livsforsikring A/S
• Sampension Livsforsikring A/S
• Velliv, Pension & Livsforsikring
• PensionDanmark
• NordikLív

The group life agreement under which you are covered dictates which companies are the data controllers for the personal data we process about you. If you would like to know who is the data controller for your personal data, you are welcome to enquire by filling out the contact form on FG’s website.

Our processing of personal data

We process your personal data in order to manage your group life insurance

We process and store your personal data for the following purposes:

• To process your application to join an insurance scheme
• To collect your premium
• To process your claim
• To pay compensation to you or your relatives
• To manage your insurance
• To process your insurance enquiries

We collect and process your personal data based on your consent or other lawful grounds

Our collection and processing of your personal data are always based on your consent or other lawful grounds. Other lawful grounds may, for example, be that FG needs to process your personal data to be able to manage your insurance or to process a claim for you.

We always require your consent if, for instance, we need to collect information about your state of health from a hospital, your general practitioner, etc.

When we request your consent to collect your personal data, we state which personal data we wish to collect, for which purposes and, if applicable, from which third parties we wish to collect personal data about you.

If we wish to use personal data we have already collected for a purpose other than that originally stated, we inform you of the new purpose and request your consent before we begin the new processing, unless we have other lawful grounds for said new processing. In such cases, we will notify you of this.

When we process personal data about children, we obtain the consent of the holder(s) of parental responsibility.

Your consent is voluntary, and you may withdraw it at any time by contacting us. You will find further details under ‘You have the right to withdraw your consent’ later in this Privacy Policy.

We process these categories of personal data about you

We only process the types of personal data about you which are necessary for the specific purpose and to the extent required.

For instance, we only process details of state of health in connection with a claim, and/or if you provide information about your state of health when you take out insurance.

The types of personal data we generally process, depending on the purpose, are listed below: General personal data, such as

• Name
• Address
• Postcode
• Telephone number
• Gender and age
• Company registration (CVR) number (if you are self-employed)
• Email address
• Insurance details
• Payment details

Confidential personal data, such as

• Civil registration (CPR) number

Sensitive personal data, such as

• State of health
• Trade union affiliations

There may also be other personal data which we process because they are required in order to fulfil a specific contract, process a specific claim or meet a legal obligation.

We ensure that your personal data are up to date

We ensure that the personal data we process about you are not inaccurate or misleading, and we ensure that they are continually updated. In order to ensure the quality of your personal data, we have adopted internal rules and established procedures for controlling and updating your personal data.

The quality of the service we provide depends on your personal data being accurate and up to date. We would therefore be grateful if you would notify us of any relevant changes to your personal data.

You can use the contact form at FG’s website to inform us of the changes, and your personal data will be sent to FG via a secure link.

We only disclose your personal data if we have your consent or there are other lawful grounds for doing so

In principle, we only disclose your personal data if we have your express consent to do so. When you provide us with your consent, we notify you of the parties to whom we may disclose your personal data. We will always notify you of the parties to whom we have disclosed your personal data.

However, in accordance with legislation, we may be obliged to disclose data to public authorities, such as the tax authorities.

We only process your personal data if we have a valid purpose

We are well aware that your personal data should not be processed for longer than necessary for the purpose intended.

When the purpose for the data processing no longer exists, we erase your personal data. This is unless we are required by law to store them until expiry of a specified limitation period, after which they will be erased. This means that your personal data are erased no later than ten years after termination of the insurance contract. However, there may be special circumstances which require us to process your personal data beyond this ten-year period, e.g. if a legal claim has been established and exercised.

We protect your personal data

We protect your personal data while we process them, and we have adopted internal guidelines for data protection, which contain instructions and measures for protecting your personal data against unauthorised access, alteration and erasure.

In this context, we have established procedures for allocating access rights to FG employees who process personal data, and we monitor these employees’ actual access through logging and surveillance. In addition, all of FG’s employees have a duty of confidentiality regarding your personal data.

We also protect the confidentiality of your personal data by means of encryption, and we take regular backups to prevent loss of personal data.

We have appointed a data protection officer

We have appointed a data protection officer who helps ensure that FG follows good data protection practice.

You can contact FG’s data protection officer at dpo@fg.dk or using our contact form, and your enquiry will be sent to FG via a secure link.

The data protection officer makes an effort to reply to all enquiries as quickly as possible.

Your rights

You have the right to receive notification if your personal data are not collected from you

You have the right to receive notification at any time if we collect personal data about you from sources other than yourself. FG will always notify you of the sources from which we collect personal data about you as well as of the purpose for which the personal data are collected.

You have the right to receive information about which personal data we process about you

You have the right at any time to request information about which personal data we process about you, the origin of these data and the purpose for which FG processes your personal data. You are also entitled to information on how long we keep your personal data as well as who receives your personal data if we disclose them.

However, the right of access may be limited out of consideration for the protection of the privacy of other persons.

You have the right to request correction of inaccuracies in personal data

You have the right at any time to request correction of the personal data we process about you if they are inaccurate. In this case, we would ask you to contact us and notify us of the inaccuracies and how we may correct them.

We inform you and any third parties to whom your personal data have been disclosed of any correction of your personal data.

You have the right to withdraw your consent

You have the right to withdraw your consent at any time. In principle, withdrawal of your consent will mean that processing of the data for which you have previously given your consent will stop, unless there are other lawful grounds for the processing. If this is the case, we will, of course, inform you of such. The withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal.

You may withdraw your consent by filling out the contact form and sending it to FG. You must state that you wish to withdraw the consent you gave for processing of your case. Please note that your consent is only valid for one year from the date of your signature on the declaration of consent.

You have the right to obtain erasure of your personal data when the purpose for processing the data is no longer applicable

If you withdraw your consent, and there are no lawful grounds for the processing, you have the right to obtain erasure of your personal data. This is unless we are required by law to store them until expiry of a specified limitation period, after which they will be erased.

If you believe that your personal data are no longer necessary in relation to the purpose for which we collected them, you may request erasure of the data.

When you contact us with a request for erasure of your personal data, we check whether the conditions have been met. If this is the case, we erase the data as soon as possible within the scope of the law. We inform you and any third parties to whom your personal data have been disclosed of any erasure of your personal data.

You have the right to receive your personal data in a portable format

You have the right to receive the personal data which you have submitted to us in a digital format, and which are processed automatically, e.g. electronic Declarations of Health, in a portable data format. We send these data either to you or to a data controller appointed by you.

You have the right to object to our processing of your personal data

You have the right to object to our processing of your personal data. If your objection is legitimate, we will discontinue processing your personal data.

You have the right to restriction of processing of your personal data

You have the right to request restriction of processing of your personal data at any time. In certain cases, you have the right to obtain restriction of processing of your personal data such that your personal data cannot be processed except for storage.

When you contact us with a request for restriction of processing of your personal data, we check whether the conditions have been met. If this is the case, we restrict processing.

We inform you and any third parties to whom your personal data have been disclosed of any restriction of processing of your personal data.

Please use our contact form if you wish to exercise your rights

If you wish to exercise your rights, we recommend that you use the contact form on FG’s website to contact us. Your enquiry will be sent via a secure link. However, you are always welcome to contact us using the details below if you prefer.

Forenede Gruppeliv

Krumtappen 4, 1st floor

2500 Valby

Telephone no.: +45 39 16 78 00
Website: www.fg.dk

Contact form: https://www.fg.dk/fakta/kontakt-fg-kontaktformular/

If we are unable to respond to your enquiry within a month, we will inform you of the reason for this and when you can expect a reply.

You have the right to complain to the Danish Data Protection Agency

If you wish to complain about our processing of your personal data, you should initially contact us directly. However, you always have the option to complain to the Danish Data Protection Agency, which is the relevant regulatory authority.

You will find the Data Protection Agency’s contact details at www.datatilsynet.dk.

This Privacy Policy was last updated on 10 February 2021