Unntatt offentlighet:
Offl §13 jfr Fvl §13 nr 1
Deres referanse Vår referanse Dato
19/01274-6/AKU 18.05.2020
A56ID 64543 – Cross-border case - Protector Forsikring ASA – Closure of case.
We refer to your complaint recieved by the Danish Data Protection Authority (DPA) on
February 10th 2019 against Protector Forsikring ASA, about their refusal to provide access to
an opinion prepared by the Protector Forsikring Danmark’s doctor.
The Danish DPA sent inquiry to Protector Forsikring Danmark in a letter dated 13 March
2019, to establish if this was a cross-border case and which authority should handle the
complaint. Protector Forsikring Danmark answered on April 1st 2019 that Protector
Forsikring ASA in Norway is data controller in the meaning of the General Data Protection
Regulation (GDPR). They confirmed that the head office in Norway makes decisions in
relation to the purposes and means of processing personal data in Protector Forsikring
Danmark and has the power to have those decisions implemented.
Therefore, the Norwegian Data Protection Authority took over as Lead Authority handling
your complaint on April 11th 2019.
We requested information from Protector Forsikring ASA in a letter dated 9 December 2019
and asked among other things why they did not regard the personal data in the doctor’s
opinion as covered by the right of access in GDPR art. 15 and about their routines for
handling of access requests.
Protector Forsikring answered in a letter dated 19 December 2019 that they are of the opinion
that you should get access to the personal data you requested and that they will send a copy of
the personal data to your attorney on 20 December 2019 at the latest. They also explained
their routine of access requests.
In the light of this information we decide to close this case. If you disagree with our decision
you have the right to send a complaint to us pursuant to Norwegian Public Administration Act
section VI, within three weeks from the day you received this letter.
Postadresse: Kontoradresse: Telefon: Telefaks: Org.nr: Hjemmeside:
Postboks 458 Sentrum Tollbugt 3 22 39 69 00 22 42 23 50 974 761 467 www.datatilsynet.no
0105 OSLO
We apologize for the excessive time it has taken to handle your case.
With kind regards,
Kopi til: Datatilsynet i Danmark, Borgergade 28, 5 sal, 1300 København, DK
PROTECTOR FORSIKRING ASA, Postboks 1351 Vika
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