92 | Annual Report 2018 responsibility to ensure that the IT solutions which it uses comply with the requirements of administrative law. Thus, it is the responsibility of the Labour Market’s Holiday Fund to ensure that, as a public sender, it is able to receive and handle communications which are sent to it via Digital Post. As the Fund had replied – after the Ombudsman had opened the case – to all communications which it had received via Digital Post and had taken relevant mea­ sures in order to avoid a similar situation in the future, the Ombudsman took no further action on the matter. 2018-32. Minutes of board meetings from company had not been ‘received by’ Danish central bank The Danish central bank, Danmarks Nationalbank, denied a journalist access to minutes of board meetings of Bankernes Kontantservice A/S, a company set up by the Danish Bankers’ Association and the central bank to improve the safety and efficiency of cash handling for Danish banks. The minutes had been sent to the Governor of the cen­tral bank at his workplace at the central bank. The Ombudsman was informed that the Governor had been appointed a member of the board of the company by the central bank. The grounds given by the central bank for its refusal of access were that the minutes had not been received by the central bank in its capacity as an authority and were therefore not subject to the right of access under section 7(1) of the Access to Public Administration Files Act. The Ombudsman pointed out that the circumstance that the minutes had been sent to the Governor of the central bank and had been registered in the electronic records system of the central bank did not in itself have the consequence that the minutes could be considered to have been ‘received by’ the central bank. In this connection, the Ombudsman gave weight to information that the material was kept separate from the other cases of the central bank and was subject to access restriction and that it had not been used in any other cases of the central bank. The Ombudsman was of the opinion that the fact that the secretary to the Governor, the Head of Cash Supply and the Chief Legal Officer of the central bank also had access to the minutes was not grounds for considering the minutes to have been received by the central bank. The Ombudsman explained that based on the White Paper on the Access to Public Administration Files Act, it is to be presumed that a public employee who has been appointed a member of the board of a company by the authority by which he or she is employed may spar with, for instance, employees of the authority who have special expertise in a specific field without the consequence that any material to which such employees are given access in this connection is to be considered to have been received by the authority. On that basis, the Ombudsman could not criticise that the central bank had denied the journalist access to the minutes.