Reporting by airlines
In connection with international flights to Denmark, airlines must register:
- First name and surname
- Telephone number
- Flight number and seat number
The data must be disclosed to the Danish Patient Safety Authority no later than three hours after arrival at a Danish airport, however, no later than 08.00 CET the following day if the arrival of the flight is after 19.00 CET.
E-mail address for contact and form submission: firstname.lastname@example.org
Obligation to disclose ordinary data on passengers
The act contains an express requirement that an airline must disclose ordinary data on crew and passengers when landing in Denmark. The airline official must disclose the data to the Danish Patient Safety Authority at his or her own initiative. This follows from section 2(1) of the Executive Order on airline officials’ obligation to register and disclose data on passengers and crew members in connection with handling of the COVID-19 situation.
Relation with General Data Protection Regulation (GDPR)
Data on passengers’ name, telephone number and flight and seat numbers constitute ordinary data (non-sensitive personal data) in accordance with the General Data Protection Regulation. It is legal to disclose ordinary personal data if necessary for the performance of a task carried out in the public interest. Infection prevention is regarded as a necessary task in the public interest. Infection prevention is regarded as the performance of a task carried out in the public interest.
The Executive Order has been issued pursuant to section 13a of Danish Consolidation Act no. 1444 of 1 October 2020 on Measures against Infectious and Other Communicable Diseases. It follows from Danish Act no. 285 of 27 February 2021 on Epidemics, etc. that rules issued pursuant to Danish Consolidation Act no. 1444 will remain in force until they are repealed or replaced by regulations laid down in accordance with the new Danish Epidemic Act.
There is consequently an express legal authority and requirement for reporting the information to the Danish Patient Safety Authority.