Intra Group Agreement Data Protection

Intra Group Agreement Data Protection Template for Denmark

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Document background

The Intra Group Agreement Data Protection is essential for corporate groups operating in Denmark who need to establish a comprehensive framework for handling personal data across their organization. This agreement becomes necessary when multiple group entities share, process, or transfer personal data between them, ensuring compliance with the EU General Data Protection Regulation (GDPR) and the Danish Data Protection Act (Databeskyttelsesloven). It addresses key requirements including data processing principles, security measures, data subject rights, and breach notification procedures. The document is particularly important for groups with Danish operations or those subject to Danish data protection law, as it incorporates specific national requirements while maintaining alignment with broader EU regulations. It helps organizations demonstrate compliance, manage risks, and establish clear accountability for data protection across the group structure.

Suggested Sections

1. Parties: Identification of the group entities participating in the agreement

2. Background: Context of the agreement, group structure, and purpose of data sharing arrangements

3. Definitions: Key terms used in the agreement, including GDPR-specific terminology and group-specific definitions

4. Scope and Purpose: Detailed description of data processing activities covered and purposes of processing within the group

5. Roles and Responsibilities: Clear designation of controllers, processors, and joint controllers within the group structure

6. Data Protection Principles: Implementation of GDPR principles including lawfulness, fairness, transparency, purpose limitation, data minimization

7. Legal Basis for Processing: Specification of legal grounds for data processing and transfer within the group

8. Security Measures: Standard security measures applicable across the group for protecting personal data

9. Data Subject Rights: Procedures for handling data subject requests and ensuring rights across the group

10. Data Breach Notification: Internal procedures for breach notification and coordination within the group

11. Audit and Compliance: Internal audit procedures and compliance monitoring within the group

12. Term and Termination: Duration of the agreement and conditions for termination

13. Governing Law and Jurisdiction: Specification of Danish law as governing law and jurisdiction arrangements

Optional Sections

1. International Data Transfers: Required when group includes entities outside the EEA, detailing transfer mechanisms and safeguards

2. Special Categories of Data: Required when processing sensitive personal data, detailing additional safeguards and procedures

3. Data Protection Impact Assessments: Required when processing is likely to result in high risk to individuals

4. Joint Controller Arrangements: Required when multiple group entities act as joint controllers

5. Sub-processing: Required when group entities may engage external processors

6. Local Data Protection Requirements: Required when specific Danish law requirements need separate attention

Suggested Schedules

1. Schedule 1 - Processing Activities: Detailed description of processing activities, including categories of data and purposes

2. Schedule 2 - Technical and Organizational Measures: Specific security measures and controls implemented across the group

3. Schedule 3 - Data Transfer Map: Map of data flows between group entities including roles and categories of data

4. Schedule 4 - Contact Points: List of DPOs, privacy officers, and key contacts for each group entity

5. Schedule 5 - Standard Forms: Templates for data subject requests, breach notifications, and other standard procedures

6. Appendix A - Group Structure: Diagram and description of participating group entities and their relationships

7. Appendix B - Audit Requirements: Detailed audit procedures and compliance checking requirements

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Intra Group Agreement Data Protection Template for Denmark

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