Field Notes

source

When can you process personal data

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The Danish Data Protection Agency’s (Datatilsynet) official English guidance on lawful processing of personal data, including its two specially regulated categories: criminal-offence information and the CPR personal identification number. The saved snapshot is the live page, with the .raw.html companion kept as the provenance copy.

What the page establishes

Denmark treats its population-register number as confidential by statute:

  • “Personal identification numbers may not be published unless consent has been given.”
  • Private bodies may process CPR numbers only under legislation, with express consent, for scientific or statistical purposes, or where disclosure is a natural part of that kind of business and essential for unambiguous identification.
  • Criminal-offence information may be processed by private bodies only with express consent or where a legitimate interest clearly outweighs the data subject’s, and may not be disclosed without consent except under the same balancing test.

Combined with the Central Crime Register’s rules (individuals receive only their own record; disclosure to private persons requires interests that clearly outweigh secrecy), the Danish architecture makes the Swedish combination — a publicly usable universal identifier plus a commercial conviction database — unlawful by construction.

Limitations

Guidance pages summarize; the operative text is the Danish Data Protection Act and sector statutes. The page does not address what Danish authorities must hand out under the Danish access act (offentlighedsloven), which is narrower than Sweden’s principle of public access but not empty.

Significance for the wiki

The Danish counter-model: the same Nordic population-register infrastructure as Sweden, with the identifier legally confidential and conviction data locked to the data subject. Denmark demonstrates that nothing about Nordic administration requires Sweden’s exposure choices. Anchors the Danish row of Public-by-default identity in international comparison.

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