Privacy policy for Diers IVF ApS – Patients and egg donors

Processing of information
As a patient/donor in Diers IVF, we collect and process a number of personal information about you. This privacy policy describes how Diers IVF processes, uses and discloses your personal information.

Types of information
Diers IVF collects and processes the following types of personal information about you:

Common categories of personal information
The patient’s (including the donor’s/depositor’s) name, social security number (cpr-number), e-mail, home address, telephone number and weight, height, smoking / alcohol habits, photo ID, bank details, social conditions, family relationships, working relationships / education, information about the patients choice of donor sperm / eggs (type and donor name). The patient’s partner’s (if any) name, social security number (cpr-number), weight, height and smoking / alcohol habits. For egg donors in addition baby photos, hobbies, childhood memories, personality, etc. for use in the donor profile.

Special categories of personal data (“sensitive personal data”)
Race or ethnic origin

Health information (patient/egg donor), including medical record information regarding. various health conditions, diagnoses, medical history, the treatment you are undergoing, test results, tests, X-rays etc.

Sexual relationships or orientation in the form of information about possible partner and marital status – thereby indirect information about sexual observance for patient and possible partner.

Genetic data (blood test from patient/donor in certain cases).

We process your personal information for the following purposes:

  • The main purpose of processing personal data is to carry out the medical treatment of our patients and egg donors in accordance with current regulations and healthcare standards.
  • To comply with the standards set for quality and safety in the collection, testing, processing, preservation, storage and distribution of gametes as well as assisted reproduction with gametes. The rules are laid down in the EU directive on tissues and cells and implemented in Danish legislation in the Tissue Act (Vævsloven), the Tissue Order (Vævsbekendtgørelsen), the Act on Assisted Reproduction in connection with treatment, diagnostics and research, etc. (Lov om assisteret reproduktion) and Executive Order on Assisted Reproduction (Bekendtgørelse om assisteret reproduktion), e.g.:
    • Investigation of serious adverse events and side effects
    • Screening of egg donors
    • Compliance with rules on geographical spread and number of donor children with donated gametes
    • Ensuring traceability from donor to recipient and vice versa
  • Comply with our obligations under applicable law, including the Tissue Act (Vævsloven), the EU Data Protection Regulation, the Data Protection Act (Databeskyttelsesloven), the Record Keeping Order (Journalføringsbekendtgørelsen) and other relevant health law legislation, e.g.
    • Documentation / record keeping obligation.
    • Compliance with basic principles for the processing of personal data and legal authority for the processing.
    • Implementation and maintenance of technical and organizational security measures.
    • Investigation of suspected or knowledge of security breaches and reporting to individuals and authorities.
    • Handling inquiries and complaints from data subjects and others.
    • Handling inspections and inquiries from regulators.
    • Dispute resolution with registered and third parties.
    • Statistical studies and scientific research.
  • Creating a donor profile for our egg donors

When we collect personal information directly from you, you provide the personal information voluntarily. You are not obliged to provide this personal information to us. The consequence of not giving us the personal data will be that we can not fulfill the purposes above, and that as a result we will in many cases not be able to process you.

In some cases, we collect personal information about you from other healthcare professionals (by prior arrangement with you) or from laboratories in connection with testing. Furthermore, we gather information about test results from the Laboratoriesvar portal for both patients and egg donor. We process the information received in accordance with this Privacy Policy.

Disclosure of personal information
To the extent necessary in the specific process, your personal information will be passed on and shared with the following recipients,

  • Authorities, when required by the rules of tissue law, assisted reproduction law and special law – e.g. The Danish Patient Safety Authority, the Danish Health Authority, the Danish Health Authority (SEI), the Joint Medicines Card, the Police and social authorities to the extent that there is an obligation to do so in accordance with current Danish legislation
  • Other fertility clinics, hospitals or healthcare professionals by prior specific agreement with the patient /egg donor / depositor, or by referral
  • Laboratories when submitting laboratory samples
  • Pharmacies and the Danish Medicines Agency via the prescription server when issuing prescriptions
  • Freight companies
  • The information in the donor profile of egg donors is passed on to potential recipients of donor eggs
  • Forward emails to Diers Klinik that were mistakenly sent to Diers IVF

Legal basis for processing and disclosure of personal data
The legal basis for collecting, processing and disclosing your personal information is:

  • In the process, ordinary personal data is collected, processed and passed on in accordance with Article 6 of the Data Protection Regulation (1) (a), (b), (c) and (d), while sensitive personal data is collected, processed and passed on in accordance with Article 9 of the Data Protection Regulation. 2) (a), (b), (C), (f), (h) and (i).
  • The obligations to collect, process and pass on personal data in connection with fertility treatment with germ cells are stated, among other things. of the Rules are laid down in the Act on Assisted Reproduction (Lov om assisteret reproduktion) in connection with treatment, diagnostics and research, etc., Executive Order on Assisted Reproduction (Bekendtgørelse om assisteret reproduktion) and in EU directive on tissues and cells and implemented in Danish legislation in the Tissue Act (Vævsloven) and the Tissue Order (Vævsbekendtgørelsen) and in the Children Act (Børneloven).
  • Health information for use in further treatment when referring patients is passed on in accordance with the rules in the Agreement on Specialist Medical Assistance §§ 20-23 and the Health Act (the Danish Sundhedslov).
  • Reporting of laboratory samples to laboratories takes place in accordance with the rules in the Danish Health and Medicines Authority’s guidelines on handling paraclinical examinations pursuant to the Authorization Act (the Danish Autorisationslov).
  • In addition, we are obliged to process a number of personal data about you pursuant to Chapter 6 of the Authorization Act (Autorisationslov) , the Executive Order on Health Persons’ Records (the Danish Journalføringsbekendtgørelsen), especially sections 5-10, and Chapter 9 of the Health Act (Sundhedsloven).
  • Prescriptions for medicines are sent via the IT service The prescription server in accordance with the rules in Chapter 42 of the Health Act (Sundhedsloven) and the Executive Order on prescriptions and dose dispensing of medicines (Bekendtgørelse om recepter og dosisdispensering af lægemidler), especially Chapter 3.
  • Clinical patient data is passed on to clinical databases in accordance with the rules in sections 195-196 of the Health Act (Sundhedsloven) and the Executive Order on the reporting of information to clinical quality databases, etc. (Bekendtgørelse om indberetning af oplysninger til kliniske kvalitetsdatabaser m.v.) Data can also be passed on on the basis of a specific consent from you as a patient, if you, for example, want to participate in research projects.
  • Epicrisis, which is a short summary of the patient’s medical history and course of treatment, is sent to the referring doctor and in some cases to the referring hospital according to the rules in Chapter 9 of the Health Act (Sundhedsloven).
  • Your personal information is only passed on to your relatives with your prior consent in accordance with the rules in section 43 of the Health Act (Sundhedsloven).
  • In the case of deceased patients, certain personal data may be passed on to the deceased’s next of kin, the deceased’s general practitioner and the doctor who had the deceased in treatment in accordance with the rules in section 45 of the Health Act (Sundhedsloven).

Withdrawal of consent
If the processing of your personal data is based on consent, you have the right to revoke the consent. If you revoke the consent, it does not affect the processing prior to the revocation of the consent, including a disclosure based on consent.

Use of data processors
Your personal information may be processed and stored by our data processors, who store it on behalf of and following instructions from us. Our data processors include:

  • IT software provider
  • Secure Email Provider
  • IT company that provides backup and support services, etc.
  • Website hosting company, including domain hosting company
  • Test laboratories

Storage period
We store personal information about you for as long as we need to carry out the stated purposes. However, according to the Executive Order on Record Keeping (Journalføringsbekendtgørelsen), we have a duty to keep these for a minimum of 10 years and according to the Tissue Act (Vævsloven ) and the Executive Order on Human Tissues and Cells (Vævsbekendtgørelsen), we have a duty to keep certain information for a minimum of 30 years after the latest entry in the record. There may be cases where we are forced to keep your personal information for a longer period of time, e.g. in connection with a complaint case, cases of serious side effects / adverse event in connection with donated germ cells or compensation case, in which case information will be kept until the case is finally closed.

Your rights
According to the data protection regulation, you have a number of rights in relation to Diers IVF’s processing of your information. You can exercise your rights at any time. To exercise your rights, contact Diers IVF.

Your rights are:

  • Right to see your information (right of access)
    You have the right to access the information we process about you, as well as a number of additional information.
  • Right to rectification (correction)
    You have the right to have incorrect information about yourself corrected. Diers IVF has a duty to take a position on the request.
  • Right to delete
    In special cases, you have the right to have the information deleted before the time at which it would otherwise be deleted. Diers IVF has a duty to take a position on the request.
  • Right to limitation of treatment
    In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to have the processing restricted, we may in future only process information – other than storage – with your consent, or for the purpose of a legal claim being established, asserted or defended, or to protect 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 the rights in the Danish Data Protection Agency’s guide to the data subjects’ rights, which can be found at

Contact or complain
If you have any questions regarding the processing of your personal data, the exercise of your rights, or you wish to complain, please feel free to contact us.

Inquiries can be made to:
Diers IVF ApS (CVR 42054240)
Store Torv 8, 4th floor
8000 Aarhus C
CEO Helle Sejersen Myrthue (e-mail:

If this does not lead to clarification, any complaint can then be directed to the Danish Data Protection Agency (Datatilsynet). The current contact address can be found at

Date: Version March 8, 2024.