Data retention policy

Last updated 15 November 2022 at 11.30 am

1. General guidelines on retention of data

The purpose of this Data Retention Policy is to help establish and provide information on the concrete retention periods which Freetrailer Danmark ApS (“Freetrailer”) applies to the different types of personal data which Freetrailer may collect and process.

As a data controller with respect to the collection and processing of the personal data which this Retention Policy relates to, Freetrailer must introduce guidelines for when such personal data are erased.

Erasure of personal data is understood to mean that data is removed from Freetrailer’s physical and digital archives and storage, such that Freetrailer can no longer process this data. Erased personal data must be erased fully from all media, on which it may have been stored, and in such a way that the personal data in question cannot be restored.

It is also Freetrailer’s responsibility, as data controller, to ensure that any data processors and any sub-contractors thereof also erase the personal data in question. Freetrailer conducts regular checks to ensure that this erasure of the affected personal data is in fact being performed.

Freetrailer erases all personal data collected without undue delay at one of the following times, whichever comes first:

  • At such time as the processing of the affected personal data is no longer necessary for fulfilment of the purpose, for which this personal data was collected;
  • At such time as Freetrailer no longer has a proper legal basis to continue processing the affected personal data.

Notwithstanding the above, Freetrailer may in some cases be required by applicable legislation to retain personal data for a longer period of time. In such cases, Freetrailer will restrict processing of the affected personal data to such activities which are specifically required by the applicable legislation.

2. Categories of data subject

Freetrailer collects and processes personal data concerning the following categories of persons:

  • Employees
  • Customers
  • Suppliers
  • Consultants/freelancers
3. Personal data concerning employees

With regards to employees, Freetrailer collects and processes the following types of personal data:

  • Name, address, telephone number, e-mail address;
  • Danish CPR no., age;
  • Tax information, salary information, and bank details;
  • Health-related information in connection with any sick days taken by the employee, including doctor’s notes, return to work notes, and any doctor’s reports;
  • Information about any trade union membership;
  • Criminal records;
  • Information about exam results and other qualifying tests;
  • Information concerning personality tests and other individual tests;
  • Documentation on further education and any courses;
  • Information concerning development plans, documentation from employee performance reviews, and concerning professional assessments of the employee in question;
  • Information concerning any occupational injuries and workplace accidents;
  • Any (written) warnings;
  • Any other internal notes concerning the employee in question;
  • Information concerning the employee’s use of Freetrailer’s IT equipment and professional use of telephones and internet connections;
  • Any photograph(s) of the employee in question and contact details for a next-of-kin.
  • Freetrailer’s company cars are fitted with GPS that indicates where a company car is at all times.
  • Freetrailer may also collect and process other information concerning health or religious affiliation, but only to the extent that such may be necessary or relevant for the affected employee’s safety and security, wellbeing, function in the workplace, or performance of duties.

Personal data concerning employees is erased as follows:

  • Personal data that may have been collected in connection with recruitment processes, including where positions have been advertised and in the event that unsolicited applications are received, and where the applicant has been rejected are erased no later than 6 months after the rejection, unless the applicant consents to their data being stored for longer.
  • Personal data concerning an employee’s name, address, tel. no., e-mail address, CPR no., age, tax information, and salary information is erased immediately 5 years after this employee’s employment ends.
  • Personal data concerning an employee’s health is erased as soon as possible after the health matter ends. However, if this health matter could have had an impact on the employment, the corresponding personal data will be erased immediately 5 years after this employee’s employment ends.
  • Personal data concerning an employee’s affiliation with a trade union is erased immediately 5 years after their employment ends.
  • Criminal record information which is collected for use in a recruitment process where the applicant obtains employment is erased immediately after the end of the hiring process.
  • Personal data concerning an employee’s personal and professional qualifications, development and education are erased immediately 3 years after this employee’s employment ends, unless the data in question could have had an impact on the employment, in which case the data shall be erased immediately 5 years after this employee’s employment ends.
  • Personal data concerning occupational injuries and workplace accidents is erased immediately 3 years after this employee’s employment ends.
  • Personal data concerning (written) warnings are erased as soon as possible once they can no longer be considered relevant for the employment. However, if these (written) warnings could have had an impact on employment, they shall only be erased immediately 3 years after the end of the incident which may have given rise to such (written) warning(s).
  • Internal notes concerning an employee are erased as soon as possible once they can no longer be considered relevant for the employment. However, if the information in such internal notes could have had an impact on employment, these notes shall only be erased immediately 5 years after the employment ends.
  • Data concerning an employee’s use of Freetrailer’s IT equipment and professional use of telephones and internet connections is erased immediately 3 years after this employee’s employment ends.
  • Photographs of an employee and contact information for a next-of-kin are erased immediately after this employee’s employment ends.
4. Personal data concerning customers

With regards to customers, Freetrailer collects and processes the following types of personal data:

  • Name, address, e-mail address, telephone number;
  • Credit card information, purchase history;
  • Driving licence no./personal ID no.;
  • Vehicle registration no.

Personal data concerning customers is erased as follows:

  • Information concerning a customer’s name, address, e-mail address, and tel. no. is erased immediately 5 years after the transaction, in which the information in question was collected, ends. However, if the transaction in question is related or otherwise connected to other transactions in such a way that it can be reasonably stated that the transactions are related, the information shall only be erased 3 years after such other transactions end.
  • Information concerning a customer’s age and date or birth, and information concerning a customer’s purchase history are erased within the same timeframe as for the customer’s name and address.
5. Personal data collected via supplier relationships

With regards to suppliers, Freetrailer collects and processes the following types of personal data:

  • Name, name of company the person is employed by, address, e-mail address, tel. no. of contact persons.

Personal data collected via supplier relationships is erased as follows:

  • Information concerning name, address, e-mail address, and tel. no. of contact persons is erased immediately 3 years after the supplier relationship ends.
6. Personal data collected via questionnaires/newsletters

With regards to surveys and newsletters, Freetrailer collects and processes the following types of personal data:

  • Name, address, e-mail address, telephone number;
  • Shopping habits.

Personal data collected via questionnaires/newsletters is erased as follows:

  • After 5 years or upon Freetrailer being contacted.

RETENTION POLICY IN TABLE FORM

  • EMPLOYEES
  • TYPES OF DATA:

    Retention period:

  • Data from recruitment process (if candidate rejected)

    Max. 6 months from rejection.

  • Name, address, e-mail address, tel. no.

    5 years from end of employment.

  • Danish CPR no., age;

    5 years from end of employment.

  • Tax information, salary information, and bank details;

    5 years from end of employment.

  • Health-related information (doctor’s notes, return to work notes, doctor’s certificates)

    Erased as soon as possible after health condition ends. Alternatively, retained for 5 years after employment ends, if health condition could have affected employment.

  • Trade union membership

    5 years from end of employment.

  • Criminal records

    Erased immediately after end of hiring process.

  • Exam results and other qualifying tests, Personality tests and other individual tests, Further education and any courses & Development plans, employee performance reviews, professional assessments

    3 years from end of employment. Alternatively, retained for 5 years after employment ends, if this information could have had an impact on employment.

  • Occupational injuries and workplace accidents

    3 years from end of employment. Alternatively, retained for 5 years after employment ends, if this information could have had an impact on employment.

  • (Written) warnings

    Erased as soon as possible once they are no longer relevant for the employment. Alternatively, retained for 3 years from such time as the incident ended, if they could have had an impact on employment.

  • Other internal notes

    Erased upon end of employment. Alternatively, retained for 5 years after employment ends, if these notes could have had an impact on employment.

  • Use of IT and telephony

    3 years from end of employment.

  • Photographs and contact details for next-of-kin

    Erased upon end of employment.

  • CUSTOMERS
  • TYPES OF DATA:

    Retention period:

  • Name, address, e-mail address, tel. no., driving licence number, vehicle registration number & Purchase history

    5 years from end of relevant transaction. Alternatively, retained for 3 years from end of any other related transactions.

  • SUPPLIERS
  • TYPER AF OPLYSNINGER

    Retention period:

  • Name, address, e-mail address, tel. no. (of contact persons)

    3 years from end of supplier relationship.

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