Privacy Policy for Donor Applicants and Donors
In this privacy policy, it is described how Born Denmark ApS ('Born' or 'we') collects, processes, and discloses your personal information when you are a donor applicant, recipient of semen analysis, or an approved donor at Born.
The privacy policy applies to you if you fill out our online application form or contact form on our donor recruitment page, and if you are an approved donor at Born. Additionally, the privacy policy applies to you if you have established a private sperm storage or have received a free sperm test from us.
You can contact our departments here:
Aarhus & Copenhagen:
Born Denmark ApS
Rosensgade 11
8000 Aarhus C
E-mail: privacy@borndonorbank.dk
Phone: +45 52 39 33 11
&
Ole Suhrs gade 19, kl./st.
1354 Copenhagen K
E-mail: privacy@borndonorbank.dk
Phone: +45 51 70 01 52
Aalborg & Odense:
Born Aalborg ApS
Boulevarden 6. 1. floor
9000 Aalborg
E-mail: privacy@borndonorbank.dk
Phone: +45 21 80 10 90
&
Havnegade 18, 1. Sal
5000 Odense C
E-mail: privacy@borndonorbank.dk
Phone: +45 29 29 34 39
If you have any questions regarding our processing of your personal information, you are always welcome to contact us at:
privacy@borndonorbank.dk
Initial contact with us:
Filling out the application form:
When you fill out our application form, we collect the personal information you provide to us directly. This includes your contact information, which department you wish to be associated with, application date, your family history, including whether you or your parents are adopted, information about criminal records, certain health information, and where you heard about Born.
We process the information you have voluntarily provided in our application form in order to assess your application and assist you in booking an appointment for an initial interview and a potential test donation at one of our branches.
The legal basis for processing the information we collect in connection with your application is based on the consent you provide pursuant to Article 6(1), letter a of the General Data Protection Regulation.
Scheduling an appointment for interview/test donation:
When you schedule an appointment for an interview with one of our donor coordinators, we collect and process your contact information in order to identify you. The legal basis follows from the consent you provide when booking in our system according to Article 6(1), letter a of the General Data Protection Regulation.
Assessment of sperm quality, including non-binding sperm evaluation:
In order to undergo our donor application process, we will ask you to provide one or more sperm samples. As part of the assessment of your sperm sample, we collect and process genetic and health information about you. We also collect and process your contact information for the purpose of communicating the results of your assessment to you. The legal basis for the collection and processing of contact information follows from your consent according to Article 6(1), letter a of the General Data Protection Regulation. The legal basis for processing your genetic and health information also follows from your voluntary consent according to Article 9(2), letter a of the General Data Protection Regulation.
If you continue in the donor application process:
After the initial contact with one of our donor coordinators, it will be assessed whether you can continue in our donor application process.
Initial interviews:
If we assess that your sperm quality is sufficient to become a donor with us, we will call you in for a conversation with one of our donor coordinators. In order to assess and document your health status as well as identify you, we collect and process a wide range of information about you, including contact information, CPR number, origin and ethnicity, copy of your passport/health card/driver's license, your sexual orientation, your risk behavior (substance use or alcohol consumption), medical history for you and your family, as well as other information that may be necessary for us to assess whether you can become a donor.
We deeply rely on mutual trust and expect you to tell the truth when providing voluntary information to us during donor intake interviews. The legal basis for collecting and processing the above information is your voluntary consent according to Article 6(1), letter a, and Article 9(2), letter a of the General Data Protection Regulation, Data Protection Act §8, paragraph 2, no. 1 & §11, paragraph 2, no. 1
Medical questionnaire:
In connection with the donor application process, we will, in collaboration with you, fill out a medical questionnaire in which you voluntarily provide information about your and your family's health and medical history. The legal basis for collecting and processing your health information is your voluntary consent according to Article 9(2), letter a of the General Data Protection Regulation.
Medical examination:
In connection with the donor application process, you will need to undergo a medical examination by our doctor. If you are accepted as a donor with us, you will also undergo an annual medical check-up as part of your role as a sperm donor. We will receive, process, and store the information provided by our doctor in connection with the medical examination. You will, of course, be informed of all findings and information that the doctor concludes from the medical examination. The purpose of the medical examination is to assess whether you are medically suitable to be a sperm donor.
The legal basis for the collection and processing of your health information is your voluntary consent according to Article 9(2), letter a of the General Data Protection Regulation.
Donor contract:
As part of the donor application process, you will, together with one of our skilled donor coordinators, be informed and briefed on the terms that apply to your role as a sperm donor. In the contract, we collect and store your contact information, including a copy of your driver's license/passport/health card, as identification of your identity. The purpose of the donor contract is on one hand to thoroughly inform you about what you are committing to as a donor with us and on the other hand, a way for us to comply with our legal obligation regarding sufficient information, identification, and traceability. It is entirely voluntary whether you wish to sign a donor contract with us. However, your consent and signature are necessary for final approval as a donor. The legal basis for the collection and processing of your personal information is your voluntary consent according to Article 6(1), letter a of the General Data Protection Regulation.
Blood and urine samples:
In order for you to be accepted as a donor with us, it is necessary for you to provide blood and urine samples. We will ask you to provide blood and urine samples regularly as part of your role as a donor with us. The purpose is to test you for a range of diseases, including sexually transmitted diseases, to reduce the risk of infection and to comply with legal obligations. The legal basis for processing your genetic and health information follows from the consent you voluntarily provide by providing a urine sample/undergoing a blood test according to Article 9(2), letter a of the General Data Protection Regulation.
If you have had a sperm assessment:
If you have undergone a non-binding sperm assessment and do not wish to continue in the donor application process, or for any other reason, we will delete your personal information after a maximum of 6 months. The purpose of storing your personal information is, among other things, to provide you with the result of your sperm assessment or to answer any questions you may have in connection with the assessment.
Your sperm sample will naturally be discarded after we have assessed your sperm quality, and you do not automatically proceed in our donor application process.
If you have filled out our application form:
If you have filled out our application form but have not proceeded in the donor application process for any reason, we will typically delete your personal information within 6 months after you are notified of the rejection of your application.
If you have participated in a conversation with our donor coordinators in connection with the donor application process:
If you have attended initial conversations with our donor coordinators but have not been approved as a donor, we will delete your personal information as soon as possible and no later than one year after you have received rejection of your donor application. There may be cases where we are required to retain your personal information for a longer period in accordance with a legal obligation we may have to ensure traceability or storage of health information.
If you have undergone a medical examination or have completed our medical questionnaire:
If you have undergone a medical examination by our doctor or have completed our medical questionnaire regarding your health information and medical history, we are required according to the journaling regulations to retain your medical records for a minimum of 10 years after the last addition. There may be cases where we are obligated to retain your personal information for more than 10 years to comply with a legal obligation.
If you have been approved as a donor:
If you are approved as a donor with us and your units are sold, we are obligated to retain your personal information for a minimum of 30 years after the last clinical use of your donations. The purpose is to ensure full traceability from donor to recipient/donor child, including for the investigation of any genetic diseases that may arise in donor-conceived children, etc. Internally, we have decided to extend the retention period to a minimum of 110 years to comply with our legal obligation for traceability in the countries where we distribute. There may be cases where we are obligated to retain your personal information for longer than described above.
Your personal information may be processed and stored by our data processors, who process and store information on behalf of and according to instructions from us.
We transfer personal data to third countries outside the EU. The transfer is made to third countries where the European Commission has made an adequacy decision regarding the level of protection, or to other third countries using the European Commission's approved standard data protection clauses.
You have a number of rights under the General Data Protection Regulation regarding our processing of information about you. If you wish to exercise your rights, please contact us at:
Right to access information (right of access)
You have the right to access the information that we process about you, as well as a number of additional details.
Right to rectification (correction)
You have the right to have inaccurate information about yourself corrected.
Right to erasure
In very particular cases, you have the right to have information about you deleted before the time for our general deletion occurs.
Right to restriction of processing
In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to have processing restricted, we may only process information – except for storage purposes – with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of a person or important public interests.
Right to object
In certain cases, you have the right to object to our otherwise lawful processing of your personal data.
You can read more about your rights on the Data Protection Agency's website.
We reserve the right to change the privacy policy based on significant changes in legislation, case law, or internal procedures.
If you wish to complain about the processing of your personal data, you can always contact us at privacy@borndonorbank.dk. You also have the option to complain to the Danish Data Protection Agency at www.datatilsynet.dk
Last revised April 2024