Content
Purpose of processing personal data
Data Controller and Data Processor
The Data Protection Officer
What personal data is being processed
How long is your information stored?
Laws and regulations
Your rights as a data subject
Complaints about the processing of personal data
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Purpose of processing personal data
The purpose of the processing of yours, your child’s and any other custodial parents' personal data, is that your child can be named and that the name can be registered in the Danish CPR-register.
The processing is based on a legal requirement (see the section 'Laws and regulations').
Data Controller and Data Processor
The parish where the child resides at the time of the application is the processing authority and thus the data controller for the processing of the personal data.
If the child does not reside in Denmark, the parish where the birth is registered is the processing authority and the data controller for the naming.
If the child is born in the Southern part of Jutland, it is the municipality in Southern part of Jutland where birth is registered, that is the processing authority and thus the data controller for the processing of the personal data regardless of residence.
In some cases, the processing and data responsibility is transferred to the Agency of Family Law, cf. section 16 subparagraph 3 in the Act on Names.
The Ministry of Health and Ecclesiastical Affairs and the authorities that use the Ministry's joint systems have joint data responsibility for the processing of personal data when the processing takes place within the Ministry of Health and Ecclesiastical Affairs' remit, cf. 'Cirkulære om fælles dataansvar, no. 9447 of June 15, 2021.
The data processor of the Danish National Church is DXC Technology.
The Data Protection Officer
Questions about an authority under the Ministry of Health and Ecclesiastical Affairs processing of your personal data can be made by contacting the Data Protection Officer in the Ministry of Health and Ecclesiastical Affairs:
Senior Consultant Rasmus Paaske Larsen
Tel.: 3392 3390
E-mail: databeskyttelsesraad@km.dk
By letter: Ministry of Health and Ecclesiastical Affairs, Frederiksholms Kanal 21, 1220 Copenhagen K, Attn.: The Data Protection Officer.
Enquiries to other authorities' data protection officers should be directed to the relevant authority.
What personal data is being processed
The authority processes the following information about your child:
- Civil registration number
- Citizenship
- Desired name
The authority processes the following information about you as an applicant:
- Civil registration number or, if applicable, date of birth for a person without a Civil registration number
- Name
- Matters concerning parental custody of the child
- Address, postal code and city
- Phone number
- E-mail address
The authority may process the following information about the parent's partner, a stepparent or a foster parent:
- Civil registration number or, if applicable, date of birth for a person without a Civil registration number
- Name
- Matters concerning parental custody of the child
- Address, postal code and city
- Phone number
- E-mail address
The authority processes this information about any other custodial parent:
- Civil registration number or, if applicable, date of birth for a person without a Civil registration number
- Name
How long is your information stored?
- An application for naming a child that is approved or rejected by the processing authority will be approved, cf. 'Cirkulære om aflevering og kassation af kirkebogsarkivalier', no. 227 of December 5, 1975 stored for 5 years. The application is then deleted, anonymised or transferred to the archive in accordance with the rules of the archive legislation.
- A digital application for naming a child, that does not reach the processing authority due to technical issues, is stored in the system for 6 months, after which it is deleted.
An example of technical issues may be, for example, that a digital application for naming a child is not finally signed before the deadline, or that the person applying does not have a registered address in Denmark.
Laws and regulations
The application for a name change is processed according to the following rules:
The processing takes place based on Article 6, subparagraph 1(c) and (e) of the General Data Protection Regulation on legal obligations and the exercise of public authority, cf. The Consolidated Act on Names, § 1, § 2, and cf. Section 16 subparagraph 1 of the Consolidated Act on Names.
Processing of civil registration numbers takes place based on section 11, subparagraph 1 of the Danish Data Protection Act.
No automated decision-making or profiling is used in connection with the processing.
The processing authority may obtain relevant information from other authorities if this is necessary for the processing of the application.
You can read more about the regulatory framework here:
- ‘The Act on Names’ (Statutory Order no. 1074 of 09/08/2023)
- ‘The Consolidated Act on Names’ (Act no. 1753 of 30/12/2024)
- ‘The Consolidated Act on the Central Population Register’ (Act no. 1010 of 23/06/ 2023)
- ‘Circular on joint data responsibility in connection with the Ministry of Ecclesiastical Affairs' common systems regarding personal registration, parish band solution and elections in the national church’ (Circular no. 9447 of 15/06/2021)
- ‘Circular on the Delivery and Disposal of Church Book Records’ (Circular No. 227 of 05/12/1975)
- ‘The General Data Protection Regulation’ (EU Regulation No. 2016/679)
- ‘The Data Protection Act’ (Act no. 289 of 08/03/2024)
- ‘The Accessibility Act’ (Act no. 692 of 08/06/2018)
Your rights as a data subject
You have the following rights under the General Data Protection Regulation:
- Right of access to the data that the authority in question processes about you.
- The right to have your information corrected in certain cases if it proves to be incorrect or misleading.
- The right to object to the authority's otherwise lawful processing of your data.
- The right, in certain cases, to have information about you deleted before the date of the authority's otherwise specified deletion occurs.
- The right to transmit information (data portability) does not apply to an application for naming a child, as the processing takes place as part of an exercise of public authority that the data controller has been assigned by law.
You can read more about your rights in the 'Danish Data Protection Agency's guidance on the rights of data subjects'.
If you want to exercise your rights, including requesting access to the processing of your data or the data of the deceased by the processing authority, you must contact the relevant authority.
You can find contact information on borger.personregistrering.dk.
Complaints about the processing of personal data
You have the right to complain about the data controller's processing of your personal data to the Danish Data Protection Agency in accordance with the rules in Article 77 of the General Data Protection Regulation.
You can contact the Danish Data Protection Agency from your digital mailbox on borger.dk or by e-mail to dt@datatilsynet.dk.