Processing Personal Data
Updated on October 21st, 2019
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How the Teachers' Union for Danish Independent Schools processes your personal data
It is important to the Teachers' Union for Danish Independent Schools (Frie Skolers Lærerforening) that members, former members and others who have given the Teachers' Union for Danish Independent Schools personal data trust the union to process their data in a transparent and safe way.
Below, we have described how the Teachers' Union for Danish Independent Schools processes your data as well as the rights you have as regards this data.
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Data controller
The Teachers' Union for Danish Independent Schools is the data controller as regards data processing of the personal data we have received about you. Our contact information:
The Teachers' Union for Danish Independent Schools (Frie Skolers Lærerforening), VAT no.: 2128 6516, Ravnsøvej 6, 8240 Risskov, Denmark fsl@fsl.dk, phone +45 8746 9110
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The purpose of data processing
The Teachers' Union for Danish Independent Schools processes personal data for the following purposes:
- to administer union membership
- to perform the right to collective bargaining and negotiate the collective agreement as well as to ensure compliance with the collective agreement
- to provide the members with advice and guidance as well as legal advice
- to meet the needs of the members as regards information, communication and marketing
- to hold educational, professional and organisational meetings, courses and training
- to create policies and participate in the public debate about subjects that are relevant to the union members
- to make sure that the union members can get certain advantages in connection with their membership
- to ensure that positions of trust are represented at the schools
- to recruit members.
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The legal basis of data processing
The legal basis of the Teachers' Union for Danish Independent Schools’ processing of your personal data for the above-mentioned purposes will in most cases be one or more of the following:
- to perform our obligations under the contract that you are a part of. When you join the union, the rules in the regulations of the Teachers' Union for Danish Independent Schools will apply to you (article 6, subarticle 1, b)
- to comply with a legal obligation that lies with the Teachers' Union for Danish Independent Schools (article 6, subarticle 1, c)
- to comply with the industrial or social obligations under the law of either the union or the members as well as specific rights with a legal basis in the law or the collective agreement (article 9, subarticle. 2, b and the Danish Data Protection Act section 7, subsection 2)
- as part of the union’s legal activities as a union (article 9, subarticle 2, d)
- so that a legal claim can be established, pleaded or defended (article 9, subarticle 2, f)
- consent (article 6, subarticle 1, a, and article 9, subarticle 2, a).
Processing of data about criminal convictions takes place according to article 10 and the Danish Data Protection Act section 8, subsection 3-5.
Processing of civil registration numbers takes place according to article 87 and the Danish Data Protection Act section 11, subsection 2.
Processing of data in terms of employment takes place according to the Danish Data Protection Act section 12.
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Personal data categories
The Teachers' Union for Danish Independent Schools processes the following personal data categories:
General data
For all members, we process the following general data: name, address, e-mail address, phone number, birthday, place of employment, job title and start date of employment.Data related to your civil registration number is used, for instance, for tax reporting so that your membership fee can be deducted.
We also process data about your contact with the union by means of phone or e-mail as well as data about your registration for the union’s courses and events.
For some members, we also process data about bank account number or whether or not you have taken out a voluntary group life insurance.
In connection with an actual consultancy case, we may – depending on the nature of the case – request additional data such as information about salary, pension, pregnancy, maternity leave, education, etc.
Sensitive data
In the sense of the data protection legislation, the fact that you are a member of a union is data that is known as sensitive data. This means that most of the information that the Teachers' Union for Danish Independent Schools processes about you is sensitive data, because our processing shows that you are a member of the union.If you have been appointed a position of trust, we process that data.
In connection with an actual consultancy case, we may – depending on the nature of the case – process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs as well as data concerning health or data concerning a natural person's sex life or sexual orientation.
Data relating to criminal convictions and offences is only processed when necessary in connection with an actual consultancy case.
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Recipients or recipient categories
We process your data confidentially. Below, you can see the cases in which we disclose your data and to which recipients:
- Public authorities when required by the law.
- Collaborators or authorities for statistical purposes.
- The Teachers' Union for Danish Independent Schools regularly performs member surveys, surveys of the working conditions at the schools, and the like. In these cases, the Teachers' Union for Danish Independent Schools uses different collaborators, for instance MSI Research, VIA and the Danish Trade Union Confederation.
- If your membership fee is withdrawn from your salaries, we disclose data to your employer about the fact that you are a member of the Teachers' Union for Danish Independent Schools, if you have given your consent.
- If you register for a course, training, a meeting or an event, this will most likely take place via “NemTilmeld” (a web-based system that helps collect and manage tasks in connection with registering for and managing events). We disclose your name, your e-mail or any special wishes for food to the course venue and/or the speaker if it is necessary in order to hold the event. We send lists of participants for the purpose of car-pooling and networking.
- If we need to disclose your data in connection with an actual consultancy case, we never do that without your consent.
- In connection with cases about compliance with the collective agreement, we hand over the case to the Teachers’ Central Organization.
- If you want to use one of the union’s member offers delivered by one of the collaborators of the Teachers' Union for Danish Independent Schools (e.g., Tjenestemændenes Låneforening, Aarhus University Press, Lån & Spar Bank, Forenede Gruppeliv, Falck Healthcare A/S), the Teachers' Union for Danish Independent Schools will confirm to the collaborator that you are a member of the Teachers' Union for Danish Independent Schools.
- If you are a member of more than one union, we will disclose the necessary data for administration of the double membership, e.g., name, address, civil registration number, e-mail address and phone number to either GEW (Die Gewerkschaft Erziehung und Wissenschaft) or BUPL (Børne- og Ungdomspædagogernes Landsforbund).
- In order to be able to safeguard your interests as a union representative and working environment representative, the Teachers' Union for Danish Independent Schools regularly creates member list that are shared with the other union representatives and working environment representatives in the Teachers' Union for Danish Independent Schools, for instance in connection with car-pooling, networking meetings, courses and the like. We will not put you on the list unless you have given explicit consent.
- Data processors.
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Transfer to recipients in third countries
Transfer of data to recipients in third countries takes place within the framework of the General Data Protection Regulation.
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Where does the personal data come from?
The Teachers' Union for Danish Independent Schools collects personal data from the following sources:
- The data you have given us yourself, e.g., in connection with registration via “MitFSL” or in connection with an actual consultancy case.
- In accordance with the collective agreement, the schools/place of employment have certain obligations to give data to the Teachers' Union for Danish Independent Schools about both members and non-members.
- Union representatives.
- Data about your address is updated continuously via the Danish Central Population Register.
- In connection with an actual consultancy case, we may need to collect data for instance from a municipality or another public authority, the school, doctors, the unemployment fund or Lærernes Pension. We will never do that without your consent.
- Sources that can be accessed publicly, e.g., schools’ websites.
- Counter parties in cases, e.g., employer, lawyer or school associations.
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Storage of your personal data
We store your data as long as you are a member of the Teachers' Union for Danish Independent Schools.
We depersonalise and/or delete data about you when it is no longer necessary in order to accomplish the purpose. Thus, in certain situations, data about you may be deleted even though you are still a member of the Teachers' Union for Danish Independent Schools. The criterion for this evaluation by the Teachers' Union for Danish Independent Schools is the relevant rules relating to claims in connection with property rights and union law. As a consequence, a consultancy case will thus be deleted 10 years after conclusion of the case.
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The right to withdraw consent
If processing is based on your consent, you have the right to withdraw your consent at any time.
You can withdraw your consent by writing an e-mail to fsl@fsl.dk or send an e-mail to the employee who has handled your case.
If you choose to withdraw your consent, this does not affect the legality of us processing your personal data based on your previous consent and up until the time of withdrawal. If you withdraw your consent, it will take effect from the time of withdrawal.
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Your rights
According to the General Data Protection Regulation, you have a number of rights in relation to us processing data about you. If you want to use these rights, please contact us on phone number +45 8746 9110 or e-mail fsl@fsl.dk.
The right to see data (right of access)
You have the right of access to the data we process about you, in addition to additional data.Right to rectification (correction)
You have the right to have incorrect data about you corrected.Right to erasure
In certain cases, you have the right to have data about you deleted before the time of normal and general erasure.The right to restriction of processing
In certain cases, you have the right to have processing of your personal data restricted. If you have the right to restricted processing, we will in the future only be allowed to process data with your consent – with the exception of storage – or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.Right to object
You have the right to object to processing of your data for direct marketing purposes.The right to transmit data (right to data portability)
In certain cases, you have the right to receive you personal data in a structured, commonly used and machine-readable format and have the right to transmit those data from one data controller to another without hindrance. -
Changes to our processing of personal data
The Teachers' Union for Danish Independent Schools recommends that you use secure e-mail in your communication with us – especially if your request contains personal data or other personal information. You do that by encrypting your e-mails to us or by sending e-mails to us using “MitFSL” on our website.
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Changes to our processing of personal data
The Teachers' Union for Danish Independent Schools can, at any time and without warning, change this privacy policy with effect for the future. In case of significant changes, we will inform you in a way which will efficiently make you aware of the changes.
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Lodging a complaint to The Danish Data Protection Agency
If you want to lodge a complaint about the way in which the Teachers' Union for Danish Independent Schools has processed your data, you can contact
The Danish Data Protection Agency, Borgergade 28, 5., 1300 København K, Denmark, www.datatilsynet.dk