Privacy Policy for JURK – Legal Counselling for Women
Latest update: 09.06.2020 by Bjørk Gudmundsdottir Jonassen
1 Whom the information is directed towards:
This information is relevant to:
- Those who contact us for legal aid and guidance
- Those who are involved in a case we are assisting with
- Those who are mentioned in the documents in the cases of our clients
Legal basis, purpose and scope of the privacy policy
Below, we have set out an overview of the reasons (purpose) for us to keep and manage our clients’ personal data, what kind of personal data we manage and the legal basis for collecting and managing such data.
2 When you contact us seeking legal advice:
When you contact us because you need legal aid or counseling, we need to investigate if there is any reason for us not to help you. There are situations where we are prevented from assisting because we are already helping someone that is involved in the case. It might be a person with whom you are having a dispute, where we have already accepted to help that person. In order to investigate this, we will do a search on your name in our archives. We may also use information about your case in this assessment. If we conclude that we cannot help you, we will not register your data.
(We call this control the “independence check”, and the legal basis for doing so is that it serves a legitimate purpose under GDPR Article 6 no. 1 (f)).
If our conclusion is that we may be able to help you, we will register you and your case. We cannot promise anything regarding what we can do to help before we have started the assessment. Because our employees are students, they have to discuss all cases in groups before they can give you an answer. This is to ensure that we are able to provide correct information, even though our employees have not finished their legal education.
When we register your case, we will also register your contact information. This includes your phone number, address and e-mail. We need this information to be able to contact you, and we need your address in case we will send you a letter or send a letter on your behalf. We store this information in a secure computer program where we store all information about or clients and their cases. We might need your personal ID number, e.g. to file a complaint on your behalf. If so, we will ask you for such information when we need it. We do not record such information in our computer program directly, but if it is written in e.g. a letter of complaint, we will store the letter electronically (in our computer program).
While we work on the case, your case worker might keep printouts of the information about you and your case in a folder. The folder is kept in a box, which is stored in a locked cabinet when the case worker is not working. We destroy the folder when we have closed the case.
(When we register your data, we do so because we have agreed to do an assessment of your case, and the legal basis for doing so is GDPR Article 6 no. 1 (b)).
When we ask you to answer our statistical questions:
We ask everyone who contacts JURK to answer statistical questions. If you submit your case through our website, you will answer these statistical questions online. If we receive your case over the phone or through personal attendance, we will fill out the form for you. Before filling out the form, we will inform you that participation is voluntary and ask if you are comfortable with answering our questions.
The reason why we may help you and others free of charge is because we get funding from The Ministry of Justice and Public Security (Justis- og beredskapsdepartementet), Oslo municipality (Oslo Kommune), The Welfare Council (Velferdstinget) and others. Many of these require us to provide them with statistical information regarding how many clients we assist, how many cases we assess, where in the country our clients reside, what income our clients have, etc. This means that it is important for us to registers this information in order for us to provide them with the correct statistics and thus get the money we need to run JURK. In addition to provide legal aid, we engage in political advocacy in order to improve laws that affect our clients’ lives. Sometimes we will use statistics to make politicians aware of important issues we want them to address.
To sum up, there are two main reasons for us to ask you to respond to our statistical questions: in order for us to get funding to run JURK, and in order to help us in our political advocacy work.
When we use the statistics, we always do it anonymously. This means that no one will be
able to see how you responded to our questions. An example of how we use the statistics is “45 % of the clients JURK help do not have Norwegian as their mother tongue”, or “78 % of our clients earn less than 450 000 norwegian kroners a year”.
The statistics is deleted after 5 years.
If you do not wish to answer our statistical questions, you can protest JURKs treatment of personal data, in accordance with GDPR article 21.
(When we ask you to answer statistical questions, it is based on the Norwegian personopplysningsloven § 8 and § 9, and GDPR Article 6 no. 1 (f)).
Please contact us if you want us to delete the statistics we have collected from you.
Case management:
Sometimes we handle cases where we receive documents (such as letters) containing information about other persons than our client. We store these documents in a computer program where we collect all information about our clients and their cases. We also write minutes from conversations we have with you and others about your case. While we manage the case, your case worker might keep printouts of documents in a folder. We destroy the folder when we close the case.
(The legal basis for doing this is a “Legitimate Interest Assessment” under GDPR Article 6 no. 1 letter f).
Sometimes documents or explanations we have received from our client will contain sensitive personal data (such as information on health or criminal records) about other persons than our clients.
(We are allowed to receive such information according to GDPR Article 9 no. 2 letter f, which provides the legal basis for determining, invoking or defending a legal claim and the Personal Data Act, Section 11).
If we have written a letter in your case, we can use it for guidance in another case:
Many of those seeking our help have cases that are similar. In order for us to be able to help as many as possible, we may use some of the information in the letter we have written to you to write letters to other clients. For example, you may contact us regarding legal rights when getting a divorce. We then write you a letter informing you about your legal position. Next week, another person also seeks our help regarding a divorce. Then we may use relevant parts of the letter we have written to you to avoid rewriting the same information.
When we do this, we never include personal data about your case, only the general, legal and practical parts of the letter. The other person will not be informed about you or your case, nor that we have used the same information that we have provided for you.
(The reason why we are allowed to do this, is because it is in our interest to utilize the work in order to give further advice as stated in GDPR Article 6, no. 1 letter f.)
We hope that all our clients understand that we can help more people when we are able to reuse some of our earlier letters. You may contact us if you find it problematic that we reuse some of the information that we have provided you with. Then we will consider to prevent the information being reused in other cases.
Saving and storage of your case files
While we work on your case, we will keep the documents in the casefile of your caseworker. Your casefile will be locked away every afternoon. We will send you all the original documents that we receive regarding your case, but we will keep a copy in your file, and upload an electronic version of it. Everything we store on our data is saved to a safe storage space, behind a so-called “fire wall”. After we have helped you in your case, we will see if we still have any original documents. If we do, we will send these to you. We will then shred and delete your physical file, but we will keep the electronic version. We will delete the electronic version after 10 years.
(The reason that we store the electronic version of your file for 10 years is because it is usually as necessary both for you and for JURK. This is because your case can up again at a later time, of because some clients may contact us again after some time if they are displeased with our help. In these situations, we need to have the information saved, so that we have a possibility to find out what has happened. The legal basis for this is GDPR article 6 no. 1 letter f and GDPR article 9 no. 2 letter f.)
Usually, we will not be able to delete information and case files before 10 years have passed, but if you this this is very problematic you can contact JURK. If you contact us, we will do an extra evaluation regarding your case specifically.
If we help you in Conciliation Board (Forliksrådet) or Rent Dispute Tribunal (Husleietvistutvalget)
Sometimes we help clients when they have a meeting in a dispute tribunal, like Forliksrådet or Husleietvistutvalget. We will never take payment to help you, but to get your case treated by a dispute tribunal the tribunals require that you have to pay a small fee. You will have to pay this fee yourself. You have to transfer the amount before we send in your case to a dispute tribunal.
When you make a payment to us, this will become a part of our accounting. We keep accounting documents for 5 years. We cannot delete accounting documents before 5 years have passed.
(The reason we keep this information is that we are obligated to follow the Norwegian law on accounting. The legal basis is GDPR article 6 no. 1 letter c.)
About JURK’s data systems
We have very secure data systems that we use for storage. It is only those who work for JURK, and the persons who help us with the data systems that have access to the data that we save.
(We have to use data systems to save and treat information to a safe and secure way. The legal basis for JURK to use data systems is GDPR article 6 no. 1 letter f and GDPR article 32 and article 6 no. 1 letter c.)
3. Who we share the personal data with
The people who help us with data (IT-service) has the possibility to see the personal data saved in our data systems. They are not permitted to look at information they do not need in order to solve a data problem for JURK. They are not permitted to share the information with others.
If you give JURK authorization in your case (fullmakt), we might share information with others. However, we will not do so before we have talked to you. For example, if we write a complaint on your behalf to NAV or UDI, there might be personal data in the complaint.
4 Your rights
When we save information about you, the following are your rights:
Ask for access:
You have the right to look at all the personal data we have saved in your case. As long as we do not have to breach our confidentiality, we will give you access.
Ask for correction or deletion/removal
If we have registered personal data that is incorrect, you can ask us to correct the information, or you can ask us to delete the information. If you ask us to delete your information, we will have to evaluate if this is something we can do. There might be important reasons that JURK cannot delete the information, for example if we need to be able to document what has happened at a later time.
Complaint to Datatilsynet
If you think that we have treated your personal data in a wrong way, you can send a complaint to Datatilsynet,
5 Security
We have routines to make sure that all personal data is being kept safe. Our routines involve education of staff, and we make sure that all documents are stored in a safe way in our offices, and that all documents that are saved electronically, is stored in a safe way.
6 Changes of our privacy policy
If we change the privacy policy, we will submit the new version onto our websites. You can always see when the document was updated, on the top of the page.
7 Contact JURK
If you have any questions or comments regarding personal data, you can contact us on
JURK – Juridisk rådgivning for kvinner, Skippergata 23, 0154 Oslo
Telephone: 22 84 29 50
E-mail: post-mottak@jurk.no