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Processing of personal data

How ALS processes personal data
ALS places great importance on ensuring that clients and citizens in general who submit their personal data can rest assured that this information is being processed in a safe and transparent manner.

This section outlines the type of personal data registered by ALS and how ALS processes this data. There is also information on the data protection rights of clients and citizens in general.

1. ALS is the data controller. Below are contact details for ALS:
Arbeiðsloysisskipanin
VAT numbers: 406732, 407003, 597988

Tinghúsvegur 14
FO-110 Tórshavn
P.O. Box 3022
FO-110 Tórshavn
Email: als@als.fo.

Contact ALS’ data protection officer, Elin Maria Bærentsen, on +298 299511 or by email at elinm@als.fo.

2. Objective and legal basis of the processing of personal data
ALS processes personal data in compliance with the Law of the Løgting no. 113 of 13 June 1997 regarding unemployment services and job centre services, as last amended by the Law of the Løgting no. 129 of 20 December 2016 (the ALS Act) and government orders issued under the provisions of this Act.

The ALS Act outlines ALS’ objectives as follows:

  • To provide financial support to unemployed people
  • To help improve the conditions for unemployed people to find work
  • To manage job centre services on behalf of the Faroese labour market

3. Registration of personal data
ALS registers the following personal data:

Automatically via the national register:

  • Social security number (p-tal)
  • Name
  • Sex
  • Birthday
  • Death (date)
  • Address
  • Residential history
  • Citizenship

Voluntarily through application forms:

  • Email
  • Phone number
  • Periods with unemployment benefits and benefits through the fish factory system (the FV system)
  • Cause of unemployment
  • Benefits received
  • Account number in bank and pension provider
  • Trade union membership
  • Vacation pay
  • A-income (income taxed at source)
  • B-inntøku (income from self-employment – not taxed at source)
  • Remunerations
  • Pensions
  • Pay slips from fish factories
  • Work during benefit payment periods
  • Vacation periods
  • Sick notes
  • Internships/trainee work
  • Meeting invitations
  • Suspension of benefits
  • Refusals of job offers
  • Benefits paid by foreign unemployment services
  • CV

Registration of A-income and B-income is based on information obtained through tax authority TAKS, application forms and earned income data from fish factories in connection with the FV system.

For supervisory purposes, ALS registers details about earned income, etc. from employers. In instances leading to administrative decisions, the persons concerned will be asked to verify the correctness of the registered information.

4. Registration and classification of personal data
ALS is required by law to register data about clients and citizens in general. This data is obtained in the following two ways:

  • From application forms
  • From other public authorities and employers

Personal data is defined as any information related to an identifiable physical person. The processing of personal data is defined as any processing of such data, e.g. collection, registration, storing and sharing. Personal data may be processed through digital as well as analog mediums.

Sensitive personal data
In certain cases, ALS registers personal data which is legally defined as sensitive. Such data includes trade union affiliation, health condition, significant social problems, ethnicity, religious, political or philosophical orientation and other private circumstances.

ALS also classifies details regarding income, unemployment and unemployment benefits as sensitive data. This means that data regarding accepted job offers, job interview invitations, causes of unemployment, documentation from employers, pensions, vacation pay, remunerations, etc. is also to be regarded as sensitive personal data.

Regular personal data
Name, address, age, phone number, email address, birthday, sex and citizenship are regarded as regular personal data, i.e. not sensitive or confidential data.

5. Sharing of personal data
In cases where other public authorities are allowed access to personal data, this data will be shared. In such cases, ALS is legally obliged to ensure that proper authorisation is in place.

The public authorities that request personal data are typically Føroya Kærustovnur (the Faroese Tribunal Board of Appeals), Almannaverkið (Social Agencies) and tax authority TAKS.

Personal data may also be shared with Hagstova Føroya (Statistics Faroe Islands) for the purpose of statistical compilation.

In connection with job recommendations through the job centre, ALS may share details about names and work experience (CV) with employers.

Clients consent to this sharing in their unemployment benefits application.

6. Access to information
Personal access
Any individual registered with ALS is, in principle, entitled to access any stored personal data about themselves. When a person requests such data, ALS must, within 14 business days of the request, collect this registered data and submit a letter of response to the person, with the following information included:

  • Name and address of the requestor and the ALS representative, i.e. the name and address of ALS and the ALS CEO
  • Name and address of the relevant ALS departments, i.e. department heads and security management
  • Purpose and title of the case
  • Details of what personal data is being processed
  • The source of the personal data
  • Whether the personal data will be shared, and if so, with whom

Public access
Anyone is entitled to public (general) access, i.e. information about, personal data processed by ALS. Such requests should be processed within 14 days. The requestor is entitled to receive a letter of response containing the following information.

  • Name and address of the requestor and the ALS representative, i.e. the name and address of ALS and the ALS CEO
  • Name and address of the relevant ALS departments, i.e. department heads and security management
  • Purpose and title of the case
  • Registered person groups and types of data processed
  • Source of the personal data
  • Whether the personal data will be shared, and if so, with whom

7. Appeals to the Data Protection Agency
Pursuant to Article 30 in the Law of the Løgting regarding the processing of personal data, as amended by the Law of the Løgting no. 24 of 17 May 2004, clients and citizens in general whose personal data is registered with ALS may appeal matters relating to the processing of their personal data to the Dátueftirlitið (the Faroese Data Protection Agency).

8. Possible consequences of violating the duty of disclosure
Article 28, section 1, in the Law of the Løgting regarding unemployment benefits and job centre services, as last amended by the Law of the Løgting no. 177 of 17 December 2020 (the ALS Act) states: “If an unemployed person has submitted incorrect information to ALS, or withheld information, concerning unemployment benefits, or has unintentionally received benefits without qualifying for such benefits, undue amounts paid out may be reclaimed from the claimant.

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