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Data Ethics Policy

Introduction and background

This Data Ethics Policy has been adopted by Collectia Group in accordance with Section 99d of the Danish Financial Statements Act.

Data ethics is about responsible use of data and ethical data management includes transparency and accountability in processes and decisions, which involve the use of data. By promoting the values of respect, transparency, innovation, and passion, data ethics is about doing the right thing for people and society, and it enables Collectia Group to consider more than mere compliance with the law, but also building trust and supporting good conduct.

The policy outlines the principles that define what we should strive for in relation to data handling within Collectia Group from an ethical perspective and aims to promote a sound and ethical data culture within Collectia Group and in our business relationships.


Accountability and Transparency

Transparency and accountability are closely related and promotes trust and confidence amongst stakeholders, customers, debtors, and employees. In Collectia Group accountability is not limited to just doing our job; it is the practice of being honest and responsible for our actions in all situations and to take ownership of them.

Equality and Fairness

Within our data processing we wish to secure equal treatment of data, so no discrimination or unequal actions will take place. While handling all data equal, we also strive to treat the people behind the data in a fair way taking their specific situation into account.

Respectful and Passionate mindset

As a trusted partner, we continuously monitor and ensure that data is handled in a clear manner with due respect for the fundamental interests of our stakeholders, customers, debtors, and employees. In Collectia Group all employees are trained to have a passionate and dedicated mindset and to be enthusiastic and have the right approach.

Innovative solutions

We are committed to bring innovative solutions to our stakeholders, customers, debtors, and employees, and likewise to use innovation to positively impact the way data is processed. Collectia Group continuously evaluate our processes and systems and we are curious to find new and better methods, think differently and be at the forefront of new trends.

Security, Training, and Awareness

Collectia Group invests heavily in data protection and the Group IT organization has been strengthened with cyber security experts. Systems and controls are in place to prevent effects of cyber-attacks and monitor irregular data flows continuously. Data in Collectia Group’s possession is processed and stored in a secure manner, ensuring confidentiality, privacy, and a minimal risk of data breaches.

All employees will be introduced to Collectia Group’s principles on data ethics, including this Policy, as part of their onboarding. In addition, all staff members receive training focused on correct data handling and general cyber security awareness when starting employment and ongoing throughout the employment.
Collectia Group has adopted and implemented a number of policies of relevance to support this Data Ethics Policy in line with applicable legislation, including a Privacy Policy and an IT Security Policy.

Ethical considerations and Continuous improvement

The Groups’ focus on data ethics is based on the fact, that the Group handles large quantities of personal data and GDPR is therefore very high on the agenda in the Group. Collectia ensures that data is collected for specific and legitimate purposes and processed in a legal, respectful, and transparent manner, while making sure that the processing only includes the data that is necessary to fulfil the purpose of the processing. At the same time, Collectia always ensure that all collected data is relevant, sufficient, and up to date, as well as making sure that personal data is not stored longer than necessary, that the stored data is protected against unlawful destruction, modification or publication and that data processing takes place with respect for the individuals’ privacy.

Collectia Group strive for continuous improvement in our data handling, and conducts regular review of policies and procedures, updating these if necessary. It is important that we are on the forefront with new trends and that our organization stays up to date with best practices and legal requirements.


Data Controller

Collectia Group primarily act as an independent data controller. Therefore, we constantly work to ensure that the processing of data only takes place when necessary and for clearly defined purposes, and with technical and organizational measures that have a high level of security.

Data handled by Collectia Group is always processed in accordance with applicable laws and internal guidelines, so that all relevant risks of unintended consequences when using data are mitigated or reduced as much as possible.

Data processors

All suppliers who process data on behalf of Collectia Group have entered into a data processing agreement, where the supplier acts according to clear and specific instructions and has incorporated a sufficiently high level of security.

Basis of processing

Data is used for debt collection and credit management purposes, so that customers and debtors get the most optimal solution, including that all relevant information is easily accessible and understandable.

There is an ongoing assessment of the nature of the processing, including whether the treatment is proportionate and relevant, and whether there are any processing activities that do not have a necessary and valid reason for processing.

Internal Governance and Approval

Collectia Group is data-driven company. Therefore, we believe data ethics are important and should be anchored at the top of our organisation. As a result, the Executive Board of Collectia Group has approved this policy and, based on input received from Collectias GDPR- and Compliance Group, assesses at least once a year its content and sufficiency.

The policy applies to all Collectia Group companies.

This Data Ethics Policy was approved and adopted by the Executive Board of Collectia Group on 28 June 2023.