This privacy policy describes how your personal data is processed in connection with the provision of the website www.miljoezoner.dk, the administration of the Low Emission Zone scheme in Denmark and your use of the Low Emission Zone’s information service.

The Danish Government has called for stricter enforcement of low emission zones in Denmark. This has been introduced in the form of digital control based on automatic reading of vehicle’s registration number. The stricter controls will ensure effective enforcement of low emission zone regulations for the benefit of continued improvement of air quality resulting in improved environmental and health protection.

References to “we” and “us” are to Sund & Bælt Holding A/S. See more below.

You can also read below about the data we collect, how it is processed and who to contact if you have any questions or comments about our guidelines.

1. Data controller

The legal entity responsible for the processing of your personal data is:

Sund & Bælt Holding A/S
CVR no. 15 69 46 88

Address:
Vester Søgade 10
1601 Copenhagen V

Tel: +45 70809282
E-mail: info@miljoezoner.dk

(Hereafter referred to as “Low Emission Zones”)

2. Description of processing

Purpose #1 The processing of your passage through a low emission zone (Copenhagen, Frederiksberg, Odense, Aarhus or Aalborg).
We process your personal data in order to verify that your passage through a low emission zone is legal.

This takes place as follows:

a. We verify data from your passage, including information about your location and registration number. The registration number is checked against the data from the Central Register for Motor Vehicles to determine whether your vehicle is allowed to drive in low emission zones in accordance with the regulations. If your vehicle has a non-Danish registration number, the data will be collected from the relevant international authorities.

b. If your vehicle is allowed to drive in low emission zones, your passage data will be erased immediately. Read more about this under Retention below. If you are in a low emission zone with a vehicle that does not comply with the environmental requirements, your passage data will be forwarded to the Environmental Protection Agency in order for the Environmental Protection Agency to issue an administrative fixed penalty notice based on your passage. The purpose of the processing is, of course, to enforce the regulations on low emission zones and, in this connection, to issue an administrative fixed penalty notice to the right owner or user of the vehicle that has been in a low emission zone illegally. When necessary, we may in this connection refer to the Central Register for Motor Vehicles to identify you as the owner/user of a vehicle and to send the administrative fixed penalty notice via e-box. Information from the relevant international authorities may also be sought.

Categories of personal data
We process the following categories of personal data about you:

Re a) General personal data – all drivers:

• Video footage and images of your vehicle and registration number, vehicle type, weight, and other technical vehicle data needed to assess whether a vehicle may be in the low emission zone.

Re b) General personal data – drivers whose driving in the zone is illegal:

• In addition to the information as mentioned under a) above, the following information is also collected:

Name, address and other information, including CPR/CVR information needed to identify you as the owner/user of a vehicle and to issue an administrative fixed penalty notice. Transaction information relating to the payment of a fixed penalty notice is also retained.

Where we obtain your data
We collect information from the following sources:

• Via video footage and images of your vehicle taken by equipment located in all five low emission zones, including mobile equipment.
• Public authorities, including the Central Register for Motor Vehicles, administered by SKAT.

If you have a non-Danish registration number: the authorities of other countries for the purpose of forwarding a fixed penalty notice.

Basis for processing
We process your personal data based on the following processing basis:

The General Data Protection Regulation (GDPR) article 6.1.e (Necessary for the performance of a task in the public interest imposed by the data controller).

Automated individual decision-making
As part of the operation of the scheme, automated decisions will be made as stated in GDPR article 22. This means that if a vehicle is not allowed to be in a low emission zone at a specified time, the vehicle will automatically be registered for the purpose of forwarding the registration to the Danish Environmental Protection Agency.

Recipients
We may share your personal data with:

The Danish Environmental Protection Agency. The Agency is the public authority responsible for the low emission zone scheme and thus decides, based on passage data, whether an administrative fixed penalty notice should be issued to an owner/user of a vehicle who has driven in a low emission zone illegally.

Retention
Personal data, including video footage and images of your registration number, is stored for as long as necessary to fulfil the purposes above. In practice, the retention periods are determined as follows:

• For all recordings of images and video footage of vehicles: images of your vehicle and your registration number will be retained for a maximum of 60 days after registration of your passage with a view to verifying whether your vehicle has legally been in a low emission zone. Most of the images are erased immediately after passage. However, in some cases, it will be necessary to extract recordings for manual processing if, for example, an error has been detected in the reading.
• For recordings of information where a violation of environmental zone regulations has taken place: in this connection, retention can occur for an extended period if the images are to be used as documentation in a specific dispute or legal proceedings in accordance with the regulations. Information in this connection can be retained for up to two years until payment has been made.
• Information about payment transactions will be retained for the current year plus five years in accordance with the Danish Bookkeeping Act.

We may also retain recordings for the purpose of building a vehicle database containing vehicle data with a view to improving the deployed equipment’s recognition of vehicles when passing through control points. The vehicle database functions in such a way that information is collected about vehicles whose registration number cannot be correctly read automatically. Such cases are initially reviewed manually. Data from manual processing will be retained and will over time optimise the automatic processing of new observations of the same vehicle, and thus reduce the number of manual processes. Information in this database can be retained for a period of up to five years from collection.

If video surveillance to prevent criminal activity is used, data will be deleted 30 days after the recording is made.

Purpose #2 Statistics and website optimisation

Website user optimisation: personal data is collected through your use of our website. We use this data for statistical purposes and to optimise user experience on our website and the services we offer. See further details in our cookie-policy

Categories of personal data
We process the following categories of personal data about you:

• Cookies
  IP address

Sources
We collect information from the following sources:

• Directly from you via your browser

Basis for processing
We process your personal data as described, based on the following processing basis:

• GDPR Article 6 (1) (f) Necessary for the pursuit of our legitimate interests, including:
  – Statistics
  – Website optimisation

Recipients
We may share your personal data with:

• Suppliers, including IT suppliers, with whom we collaborate with regard to the collection of data for statistical purposes and for optimising your user experience, including in connection with the use of the website.

Retention
We will retain personal data for as long as necessary for the purposes mentioned.

• Cookies are deleted in accordance with the Low Emission Zone’s cookie policy. See cookie policy

Purpose #3 Recording telephone conversations in information service

In connection with quality assurance and training our customer service staff, we wish to record your telephone enquiry to our customer service. This is done with a view to quality assurance and the training of our staff at the Low Emission Zone’s Customer Service. However, we will only record and use the recording for training purposes if you consent to this.

Categories of personal data
We process the following categories of personal data about you:

General personal data:

• Name, telephone number and other information that your enquiry may relate to, including your registration number and penalty reference number if you enquire about a fixed penalty notice you have received.

Sources
We collect information from the following sources:

• Directly from you

Basis for processing
We process your personal data as described, based on the following processing basis:

• GDPR Article 6 (1) (a) (Consent)

Retention
We will retain personal data for as long as necessary for the purposes mentioned.

• Video footage will be retained for a maximum of 30 days from the time of recording. If a specific conversation is to be used for training purposes, it will be extracted and retained for a maximum of 90 days.

Purpose #4

Other electronic enquiries to Low Emission Zones

When you contact the Low Emission Zone’s customer service (information service), including, for example, by email, we collect information about you for the purpose of processing your enquiry.

Categories of personal data
We process the following categories of personal data about you:

General personal data:

• Name, e-mail, telephone number, registration number (if you use the search function) and other information that your enquiry may relate to, including your registration number and penalty reference number if you enquire about a fixed penalty notice you have received.

Sources
We collect data from the following sources:

• Directly from you
  By entering your registration number into the website when using the search function

Basis for processing
We process your personal data as described, based on the following processing basis:

GDPR Article 6 (1) (f) (Necessary for the pursuit of our legitimate interests, including: responding to enquiries and managing the search function)

Retention
We will retain personal data for as long as necessary for the purposes mentioned.

• Up to six months from the final response to the enquiry. However, this does not apply to:
  • Information about your transactions retained in the current year plus five years in accordance with the requirements of the Danish Bookkeeping Act.
  • Information you enter in the search function is stored for five years.

3. Transfers to countries outside the EU/EEA

In some cases, we will transfer your personal data to non-EU/EEA countries, in practice, the United States. Transfers to the U.S. will only be made for specific purposes, as mentioned in Section 2, and we will always ensure that the necessary guarantees are in place when a transfer is made to a non-EU/EEA country.

The transfers will be made through the use of “Model Contracts for the Transfer of Personal Data to Third Countries”, as published by the Commission of the European Union. You may obtain a copy of the contract/agreement by contacting us at: person-data@sbf.dk.

4. Your rights

• You have the following rights:
• You are entitled to request access, rectification or erasure of your personal data.
• You are also entitled to oppose the processing of your personal data and to request a restriction on the processing of your personal data.
• You have, in particular, an unconditional right to oppose the processing of your personal data for direct marketing purposes.
• If the processing of your personal data is based on Article 6 (1) e (in the public interest or an act of public authority) or Article 6 (1) f (balancing of interests) see above under Basis for Processing, you are entitled to oppose such processing for reasons that may relate to your particular situation.
• If the processing of your personal data is based on your consent, you are entitled to revoke such consent at any time. Revocation of your consent will not affect the lawfulness of the processing carried out prior to your revocation of your consent.
• You are entitled to receive personal data which you have provided to us in a structured, commonly used and machine-readable format (data portability).
• You can always lodge a complaint with a data protection authority, for example, the Danish Data Protection Agency.

You can exercise your rights by contacting info@miljoezoner.dk or tel +45 70809282. Such rights may be subject to conditions or restrictions. It is not certain, therefore, that you will be entitled to, for example, data portability in a specific situation. This depends on the specific circumstances of the processing.