In addition to the exemptions stated in the GDPR, no informing requirements apply, if the data subject’s interest in obtaining the information is overridden by essential considerations of private interests (DPA Section 22(1)).

This rule becomes relevant in relation to whistleblowing reports and other internal investigations, where the informing can be postponed.

Additional exemptions apply where personal data has not been obtained from the data subject, for example, if

  • processing including disclosure is explicitly set out by law or regulations or
  • making the personal data available to the data subject proves impossible or would involve a disproportionate effort.

The Danish Data Protection Agency provides a template to comply with informing requirement: https://www.datatilsynet.dk/media/6813/skabelon_til_en_aftale_vedroerende_faelles_dataansvar.docx (in Danish)