This updated version of our privacy policy enters into force on 29 November 2019.

1. Introduction

This personal data policy concerns our processing of your personal data when we are the data controller. We process your personal data in accordance with the legislation, including the General Data Protection Regulation (Regulation No. 2016/679 of 27 April 2016) and the Danish Data Protection Act (Act No. 502 of 23 May 2018). In the following privacy policy, we inform you about how Innovation Fund Denmark processes your personal data and what rights you have.

2. We are the data controller – how do you contact us?

Innovation Fund Denmark is the data controller for the personal data we process about you. Our contact details are:

Innovation Fund Denmark

Kalkværksvej 16, 7
8000 Aarhus C
Telephone no.: +45 6190 5000
Email: kontakt@innovationsfonden.dk
CVR: 29035695
Website: Innovationsfonden.dk

3. Contact details of the Data Protection Officer

If you have questions about the processing of your data, you are welcome to contact our Data Protection Officer:

Kenneth Mikkelsen, DeiC
Email: kenneth.mikkelsen@deic.dk

4. Innovation Fund Denmark ensures fair and transparent processing of personal data

When Innovation Fund Denmark asks you to provide your personal data to us, you will be informed about which data is processed about you and for what purpose. You will receive this information no later than at the time your personal data is collected.

If Innovation Fund Denmark obtains information about you from others, e.g. a public authority or a partner, you will be informed of this to the extent the Fund is obliged to do so, as far as possible within 10 days after the relevant personal data has been obtained. Innovation Fund Denmark also informs you of the purpose of obtaining the data and the legal basis that gives Innovation Fund Denmark the right to process your personal data.

5. The purpose of processing your personal data and the legal basis for it

We process personal data about, among others, applicants to the Fund’s schemes, employees and partners, to the extent necessary to carry out the Fund’s tasks and where there is a lawful basis for doing so. Below you can read more about our processing of personal data within different areas.

However, the Fund may also process personal data in other contexts. For example, if you are an applicant for a position at the Fund, you will receive separate information with further details about the processing of your data.

5.1 Applications and grants

Innovation Fund Denmark processes information about you when you are included in applications to one of Innovation Fund Denmark’s schemes (e.g. Grand Solutions, InnoBooster, InnoFounder or the Industrial PhD schemes) or in a project for which Innovation Fund Denmark has awarded a grant.

The purpose of the processing is to enable the Fund to assess whether the applicant or grant recipient (e.g. a company or a university) has the right competencies and necessary resources to carry out a project for which a grant has been applied for or awarded, to identify contact persons, to carry out financial follow-up, including paying out grants, and to administer participation in the Fund’s knowledge activities (e.g. participation in a course for industrial researchers).

The legal basis for the processing of personal data in connection with applications and grants is Act No. 306 of 29 March 2014 on Innovation Fund Denmark and Executive Order No. 1150 of 25 October 2017 on the grant function etc. under Innovation Fund Denmark, cf. Article 6(1)(e) and Article 9(2)(g) of the GDPR. Information about CPR numbers is processed pursuant to Section 11(1) of the Danish Data Protection Act.

Furthermore, the data may be used for statistical or scientific purposes, including for analysis or evaluation tasks. The purpose here is to be able to carry out statistical studies on various topics.

The legal basis for the processing of personal data in connection with statistical studies is Article 6(1)(e) of the GDPR and Section 10 of the Danish Data Protection Act.

5.2 Newsletter, events and the website

Innovation Fund Denmark processes information about you if you subscribe to our newsletter or register for one of the Fund’s events. The purpose is to be able to identify and contact you in order to administer your subscription and registrations, including sending newsletters and invitations.

In addition, we collect information via so-called cookies in connection with your use of Innovation Fund Denmark’s website. The purpose is to tailor content and functions and to analyse traffic on the website.

Cookie Policy for Innovation Fund Denmark

The legal basis for the processing of data in connection with newsletter subscriptions and cookies is Article 6(1)(a) of the GDPR on consent.

In connection with Innovation Fund Denmark’s recurring awards event, the Fund receives nominations for award recipients from others, e.g. business organisations and universities. The purpose is to select candidates to receive the Fund’s awards.

The legal basis for the processing is Article 6(1)(f) of the GDPR on legitimate interests. Innovation Fund Denmark’s legitimate interests are to be able to hold the awards event, where you may be considered for receiving Innovation Fund Denmark’s awards.

5.3 Research peer reviews

The Fund must approve the award procedure and carry out a research peer review of received applications for the individual ministers’ award of state research grants that are not basic grants linked to a specific institution or grants for research-based public authority services. In this connection, the Fund processes information about persons included in the research applications. This concerns administrative staff and researchers who are to carry out the project. The purpose is to assess whether the persons have relevant research expertise to be able to carry out the project.

Furthermore, the Fund processes information about members of research committees of other ministries when the Fund approves the composition of the committee. The purpose is to assess whether the committee has relevant research expertise.

The legal basis for the processing of personal data in connection with research peer review approval of applications and research committees of other ministries is Section 5(1) of Consolidated Act No. 1660 of 12 August 2021 on Innovation Fund Denmark, cf. Article 6(1)(e) and Article 9(2)(g) of the GDPR.

5.4 Access to documents

The Fund processes personal data in connection with handling requests for access to documents.

The purpose of the processing is to be able to respond to requests for access to documents.

The legal basis is Chapter 4 of the Danish Public Administration Act, the Danish Access to Public Administration Files Act and the Danish Environmental Information Act, cf. Article 6(1)(c) of the GDPR.

5.5 Whistleblower scheme

The Fund’s privacy policy for the processing of personal data in connection with the whistleblower scheme can be found here.

5.6 Appointment of members to committees, panels and working groups etc.

The Fund processes personal data in connection with the appointment of members to the Fund’s committees, panels, working groups etc.

The purpose of processing personal data is to be able to appoint a member to the relevant committee, panel, working group etc.

The legal basis for processing personal data as part of appointing members to committees, working groups etc. is normally Article 6(1)(e) of the GDPR, under which the Fund may process ordinary personal data when the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Fund. In some cases, the task of appointing members to committees, working groups etc. follows from specific statutory provisions.

6. The right to withdraw consent

You may withdraw your consent at any time. You can do this, among other ways, by contacting us using the contact details stated above.

If you choose to withdraw your consent, this does not affect the lawfulness of our processing of your personal data based on your previously given consent up to the time of withdrawal. If you withdraw your consent, it therefore only takes effect from that time.

7. Transfer to recipients in international organisations and third countries

Innovation Fund Denmark participates in a number of international programmes with joint programme secretariats, including EU co-funded programmes, Eurostars, EUREKA and Nordic programmes. The Fund receives applications etc. containing personal data from the programme secretariats, but the Fund does not transfer personal data to the secretariats.

Innovation Fund Denmark also participates in bi- and multilateral programmes without joint programme secretariats. In these programmes, the applicant sends the applications directly to each participating country’s administrative authorities etc.

7.1. Transfer to recipients in third countries (countries outside the EU)

In certain cases, personal data may be sent to individual external assessors (international peers) in third countries outside the EU, cf. Articles 45 and 49 of the GDPR. This may occur in the following programmes: Grand Solutions, Innomissions and international programmes with national assessment (bilateral calls with e.g. India and China as well as EUREKA programmes). The individual external assessors access the application containing personal data via the application and case management system.

8. What data is collected?

As a general rule, we only collect and process ordinary personal data, including identification data (CPR number), about you. See more about the different categories below.

8.1 Applications and grants

For applications to and project grants from Innovation Fund Denmark’s schemes, Innovation Fund Denmark may collect and process the following data:

• Contact and identification data, including name, address, email address, telephone number and CPR number.
• CV, including gender, title or job title, organisational affiliation or place of work, nationality, field of study as well as place and time, diploma (grades etc.), information about articles and granted patents, description of competencies and possibly a photo.
• Information about a person’s health (typically information about pregnancy in connection with processing a request to extend the project period).
• Company data, including information about CVR number (possibly P number), finances and VAT number.
• Bank details, including registration and account number.

8.2 Newsletter, events and the website

When registering for the newsletter and events, we collect and process the following data:

• Email address
• Name
• Title or job title
• Organisation

When using the website, we collect and process the following data:

• Type of device used – e.g. PC or tablet
• Browser type and language setting
• Partial IP address (not the last four digits)
• Information about your visit to our website (cookie)

In connection with Innovation Fund Denmark’s awards event, the categories of data stated above in connection with applications and grants are also collected and processed.

8.3 Research peer reviews

For research peer reviews of applications for other ministries’ award of state research grants, Innovation Fund Denmark collects and processes the personal data included in the research applications.

Furthermore, the Fund collects and processes information about members of research committees of other ministries when the Fund approves the committee.

In both situations, this typically concerns contact details, CVs and other ordinary personal data.

8.4 Access to documents

The Fund processes the contact details of the person making the enquiry. It may also be necessary to process other personal data in order to respond to the enquiry, typically if other personal data is mentioned in the material for which access to documents is requested. This will most often concern ordinary data, but depending on the enquiry it may also concern sensitive data.

8.5 Whistleblower scheme

The Fund’s privacy policy for the processing of personal data in connection with the whistleblower scheme can be found here.

8.6 Appointment of members to committees, panels and working groups etc.

The Fund processes contact details, CVs and other ordinary data in order to be able to appoint members to committees, working groups etc.

9. Where does your personal data come from?

9.1 Applications and grants

Most of the personal data processed by Innovation Fund Denmark comes directly from applicants to the Fund’s schemes and from grant recipients. In some cases, the applicant or grant recipient submits personal data about other co-applicants and grant recipients or potential future employees, e.g. in the form of contact details or CVs.

Innovation Fund Denmark also receives applications for research grants from the various ministries’ award of state research grants.

In connection with international programmes, the Fund receives applications from joint programme secretariats, e.g. the Eurostars Secretariat.

9.2 Newsletter, events and the website

Personal data obtained in connection with subscriptions to the Fund’s newsletters, events and use of the website comes from the person who subscribes and uses the Fund’s website.

In connection with nominations for Innovation Fund Denmark’s awards event, the Fund receives personal data about nominated candidates for the awards from others, e.g. business organisations and universities.

9.3 Research peer reviews

The Fund receives research applications, which among other things contain personal data, from the ministerial authorities that administer the research funding pools. Furthermore, the Fund receives CVs from the authorities for candidates for the ministries’ research committees, the composition of which must be approved by the Fund.

9.4 Access to documents

Contact details come from the person who contacts the Fund. For other types of data, it depends on the specific case where the data comes from.

9.5 Whistleblower scheme

The Fund’s privacy policy for the processing of personal data in connection with the whistleblower scheme can be found here.

9.6 Appointment of members to committees, panels and working groups etc.

Personal data comes from various sources, including business organisations, Universities Denmark and public authorities. Certain data is obtained from the person being appointed.

10. Storage of collected personal data

The data is stored for the period necessary and permitted under the legislation.

Below you can read more about how long we store personal data within different areas.

10.1 Application and grant cases

Application cases are registered in accordance with the rules of the Danish Access to Public Administration Files Act and transferred to the archival authorities in accordance with the rules of the Danish Archives Act (approx. every 5 years). After transfer to the archival authorities, the Fund retains a copy for approx. 5 years depending on the concurrent archival period, after which the data is deleted by the Fund.

Grant cases are registered in accordance with the rules of the Danish Access to Public Administration Files Act and transferred to the archival authorities in accordance with the rules of the Danish Archives Act (approx. every 5 years).

Grant cases where the Fund has awarded grants pursuant to the European Commission’s General Block Exemption Regulation for state aid (No. 651/2014) are stored for ten years from the time the latest aid was granted under the scheme. The legal basis is Article 12(1) of the General Block Exemption Regulation.

Grant cases where the Fund has awarded grants pursuant to the European Commission’s de minimis aid Regulation (No. 1407/2013) are stored for ten financial years calculated from the time the aid was granted. The legal basis is Article 6(4) of the de minimis Regulation.

10.2 Newsletter, events and the website

We store your data about your newsletter subscription until you unsubscribe, after which the data is deleted.

When registering for events, we store your data until four weeks after the event has been held, after which the data is deleted.

When you visit Innovation Fund Denmark’s website, cookies are stored on your own device, e.g. a computer. You can reject cookies on your computer by changing the settings in your browser. You can also delete cookies from Innovation Fund Denmark’s website on your computer. How you do this depends on which browser you use.

10.3 Research peer reviews

Documents relating to research peer reviews and approval of the ministries’ research committees are registered in accordance with the rules of the Danish Access to Public Administration Files Act and transferred to the archival authorities in accordance with the rules of the Danish Archives Act (approx. every 5 years). After transfer to the archival authorities, the Fund retains a copy for approx. 5 years depending on the concurrent archival period, after which the documents are deleted by the Fund.

10.4 Access to documents cases

Access to documents cases are registered in accordance with the rules of the Danish Access to Public Administration Files Act and transferred to the archival authorities in accordance with the rules of the Danish Archives Act (approx. every 5 years). After transfer to the archival authorities, the Fund retains a copy for approx. 5 years depending on the concurrent archival period, after which the documents are deleted by the Fund.

10.5 Whistleblower scheme

The Fund’s privacy policy for the processing of personal data in connection with the whistleblower scheme can be found here.

10.6 Appointment of members to committees, panels and working groups etc.

Documents containing personal data are registered in accordance with the rules of the Danish Access to Public Administration Files Act and transferred to the archival authorities in accordance with the rules of the Danish Archives Act (approx. every 5 years). After transfer to the archival authorities, the Fund retains a copy for approx. 5 years depending on the concurrent archival period, after which the data is deleted by the Fund.

11. Recipients or categories of recipients

We disclose or entrust your personal data in the cases described in more detail below.

11.1 External assessments

In some of Innovation Fund Denmark’s schemes (e.g. Grand Solutions), the Fund discloses applications to external subject-matter experts in order to obtain professional assessments of the applications. The guidelines for each scheme state the extent to which external professional assessments are used. The Fund also sometimes discloses applications to external subject-matter experts in order to obtain research peer reviews of applications for other ministries’ award of state research grants.

In certain cases, personal data may be sent to individual external assessors (international peers) in third countries outside the EU, cf. Articles 45 and 49 of the GDPR. This may occur in the following programmes: Grand Solutions, Innomissions and international programmes with national assessment (bilateral calls with e.g. India and China as well as EUREKA programmes). The individual external assessors access the application containing personal data via the application and case management system.

11.2 Danish Tax Agency

Innovation Fund Denmark reports information about grants to the Danish Tax Agency using the grant recipient’s CPR number, CVR number or SE number.

11.3 The Danish Agency for Governmental Administration

For the purpose of paying out grants, information about the grant recipient’s CPR number, CVR number or SE number is disclosed to the Danish Agency for Governmental Administration.

11.4 External advisers

Innovation Fund Denmark may disclose information to external advisers if needed, cf. Article 6(1)(f) of the GDPR. Innovation Fund Denmark’s legitimate interests are to be able to receive advice.

11.5 Administration of grant cases

Innovation Fund Denmark discloses personal data from grant cases to the Danish Agency for Higher Education and Science, which handles the financial administration of grant cases in several schemes.

11.6 Service providers and data processors performing work on our behalf

Innovation Fund Denmark uses service providers and data processors that perform work on our behalf, including server hosting, system maintenance and email service (e.g. Statens IT). These partners may access data to the extent necessary to deliver their services.

The partners will be contractually obliged to treat all data confidentially and are therefore not permitted to use the data for anything other than what is covered by the contractual obligation towards Innovation Fund Denmark.

11.7 Disclosure of application data for statistical and scientific purposes

Innovation Fund Denmark discloses application data, e.g. the company name, CVR number, application year, project title, project start and end date, grant amount and grant status (rejection/approval), to the Danish Agency for Higher Education and Science’s InnovationDanmark database and to others, including e.g. other public institutions (e.g. universities and ministries) and private consultants who carry out an analysis or evaluation task for a public institution.

The InnovationDanmark database is used solely for statistical and scientific purposes.

Upon request from a third party, the Danish Agency for Higher Education and Science will provide the InnovationDanmark database for statistical and scientific purposes. Typically, the third party is other public institutions (e.g. universities and ministries) and private consultants who carry out an analysis or evaluation task for a public institution.

The Danish Agency for Higher Education and Science can provide information about who has been given access to the database for statistical and scientific purposes. Further questions about the InnovationDanmark database should be addressed to Innovation Fund Denmark or the Danish Agency for Higher Education and Science.

11.8 Archives

Innovation Fund Denmark transfers personal data etc. to the Danish National Archives in accordance with the archives legislation.

12. Your rights

Under the GDPR, you have a number of rights in relation to our processing of data about you.

If you wish to exercise your rights, you must contact us.

Right of access to data (right of access)
You have the right to access the data we process about you.

Right to rectification (correction)
You have the right to have incorrect data about you corrected.

Right to erasure
In special cases, you have the right to have data about you erased before the time of our general erasure occurs.

Right to restriction of processing
In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to restriction, we may in future only process the data – apart from storage – with your consent, or for the establishment, exercise or defence of legal claims, or to protect a person or important public interests.

Right to object
In certain cases, you have the right to object to our otherwise lawful processing of your personal data.

Right to data portability
In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have this personal data transferred from one data controller to another without hindrance.

More information about rights
You can read more about your rights in the Danish Data Protection Agency’s guidance on data subjects’ rights, which you can find at www.datatilsynet.dk.

13. Complaints procedure

You also have the right to lodge a complaint with the Danish Data Protection Agency if you are dissatisfied with the way we process your personal data. You can find the Danish Data Protection Agency’s contact details at www.datatilsynet.dk.