SUMMARIES OF SELECTED STATEMENTS The Ombudsman had no grounds for criticising the Ministry’s decision. Based on the provision’s explanatory notes, the Ombudsman emphasised among other things ‒ as did the Ministry ‒ that the right to data extraction is not intended for registrations which are primarily done to serve internal administrative purposes. The security log, which was solely intended to fulfil the statutory demand for logging of all personal data use, had in the Ombudsman’s opinion to be considered a system facility derived from the actual processing of information in the CPR system. Consequently, the Ombudsman agreed with the Ministry that the provision did not provide a right to extraction from the CPR’s security log. On this basis, the Ombudsman took no further action in the matter. 2014-26. ASSOCIATION WAS WITHIN THE SCOPE OF THE ACCESS TO PUBLIC ADMINISTRATION FILES ACT A journalist complained to the Ombudsman because an association had refused a request for access to files. The grounds given for the refusal were that the association was created on a private law basis and therefore not subject to the Access to Public Administration Files Act. The association was created by a number of municipalities and other public authorities and was intended to provide IT solutions for the authorities. The Ombudsman stated that in his opinion, the association was not part of the public administration and consequently not within the scope of sections 2 or 3 of the Access to Public Administration Files Act. On the other hand, the Ombudsman was of the opinion that the association was subject to section 4 of the Act according to which the Act applies to all activities carried out by companies if more than 75 per cent of the ownership is in the hands of Danish public authorities. The Ombudsman referred to the explanatory notes for section 4 of the Act which say that, i.a., companies included in the Act on Certain Commercial Undertakings are subject to section 4 of the Access to Public Administration Files Act. The Ombudsman said that in his opinion, the association was subject to the Act on Certain Commercial Undertakings. 145