This document describes how Fjellinjen collects and processes personal data. All types of information that can be used to identify, characterise, describe or locate an individual person are considered personal data. Fjellinjen collects and processes large volumes of such data, mainly in connection with toll collection in Oslo. This document provides you with additional information about our processing and your rights once you are registered (as a “data subject”) in our systems.
1.1 Data Controller
The person or organisation that, alone or together with others, is responsible for processing personal data determines the purpose of the processing. Fjellinjen AS, org. no. 941 856 543, is solely responsible for the processing activities described in this document, unless otherwise stated in the individual sections below. Enquiries about general processing of personal data, notification of potential violations of privacy or questions about your own personal data should be sent to personvern@fjellinjen.no.
Our address is:
Fjellinjen AS
Schweigaards gate 16
PO Box 459 Sentrum
0105 Oslo
1.2 Fjellinjen’s Data Protection Officer
Fjellinjen has appointed a dedicated Data Protection Officer, whom you can contact. Enquiries addressed to our Data Protection Officer must relate to Fjellinjen’s own processing of personal data, and mainly your own personal data – for example questions about your rights to access your personal data.
You can contact the Data Protection Officer by email at personvern@fjellinjen.no or by using a dedicated form on our website. View form.
Fjellinjen collects and processes personal data in connection with the registration of toll crossings in, or on the way into Oslo, or in connection with the administration of the business, internal affairs and contact with suppliers, public agencies and other business connections or government bodies.
2.1 Registration and identification of toll crossings
In order to be able to collect tolls, Fjellinjen AS processes personal data relating to everyone who passes through the company’s toll stations. Toll collection is fully automated, from registration at the toll station through pricing, to invoicing and registration of payment. The right to collect tolls is authorised in Article 6.1 c) of the General Data Protection Regulation and Section 27 first and fifth paragraph of the Norwegian Road Act. Fjellinjen collects the tolls on behalf of the Norwegian government represented by the Ministry of Transport and Communications. The Norwegian Public Roads Administration has prepared a comprehensive list of personal data processed in Norwegian toll systems which you can view on autopass.no
Crossings at our toll stations are registered either by reading a valid toll tag, or using automatic number plate recognition. If the picture of the number plate cannot be interpreted automatically, it will be read by a member of staff. Selected images are also used to calibrate and adjust camera equipment at the toll stations to ensure accurate identification of vehicles.
When passing vehicles have been identified, the information is transferred to the Norwegian Public Roads Administration for pricing and preparation for collection. This processing is carried out by the Norwegian Public Roads Administration. You can find details of the processing on the Norwegian Public Roads Administration’s website autopass.no under “Your rights and obligations”.
2.2 Collection of tolls
If the vehicle has an AutoPASS subscription, your subscription provider carries out further processing. Crossings by vehicles that do not have an AutoPASS subscription are invoiced and followed up by Fjellinjen. We process information about the vehicle’s owner in order to issue an invoice for these crossings. We obtain this information from the Motor Vehicle Register owned by the Norwegian Public Roads Administration. In order to efficiently collect charges from customers without an AutoPASS subscription, we record payments, payment history, invoice history and information about enquiries in connection with the collection. If you pass one of our toll stations in a foreign-registered vehicle, the toll is collected by an external partner. Privacy aspects relating to the collection are safeguarded through a Data Processor Agreement that delimits the scope of the partner’s responsibilities and tasks, and clearly determines how the personal data is to be processed and managed.
2.3 Processing of exemption applications for persons with reduced mobility
Fjellinjen may process personal data in connection with applications for exemption from toll charges relating to natural persons. The processing is authorised in Article 6.1.c of the General Data Protection Regulation and Section 27 first and fifth paragraph of the Norwegian Road Act.
2.4 Visits to our website
When you visit fjellinjen.no, we register information about, for example, your IP address and how you use the site.
2.5 Use of the contact form on our website
When you contact us using our contact form we will only use personal information you provide to process and respond to the enquiry in question. The information is deleted within three months of the enquiry being closed, unless you have registered other enquiries in the same channel that have not been closed. Similar information relating to other areas of processing follows the rules for the area in question. We may also process personal data in connection with recruitment, administration and operation of the business, whistleblowing (notification) cases, privacy enquiries and invoicing. This processing is authorised in Article 6.1.c, and in some cases, Article 6.1.f, of the General Data Protection Regulation based on Fjellinjen’s legitimate interest.
2.6 Logging into our self-service solution “My Page”
We use the solution ID-porten for secure login and to identify anyone who uses the solution. We receive information about your name and address from the National Population Register for secure identification against our own systems. This data is automatically deleted six months after your last login. Any invoice data you retrieve and display in the solution will be automatically deleted after 30 days. If you contact our credit department, the information you provide in connection with your enquiry will be stored in the system for as long as is necessary to deal with the enquiry. Closed dialogues are automatically deleted after one year.
2.7 Applying for a job at Fjellinjen AS
If you have responded to one of our job adverts, we will register and store your application data for as long as the application process is ongoing. When the recruitment process is finished, all applicant data that is not relevant to the actual recruitment will be deleted. Applicant data that is registered via an application portal, for example finn.no, is processed according to the applicable portal’s regulations. See the privacy policy on the individual job applicant portal for information about how your application data is processed and how you can exercise your associated rights.
The following 23 categories of personal data are processed in the toll systems. For each individual, we only process the categories for which we have information and which are necessary and relevant.
In the case of category 4 (ID number), only date of birth is normally processed. National insurance numbers/D numbers are only processed when this is submitted by the customer. Photos/films taken when passing toll stations do not show people in vehicles.
You are entitled to know what information we have stored about you and to request that inaccurate information be corrected or supplemented. You also are entitled to request the disclosure or deletion of personal data. Data may only be deleted if this does not contravene other legislation, for example relating to the retention of accounting information. In some cases, you can also ask us to restrict how much of your personal data we process. You can send enquiries about your rights to personvern@fjellinjen.no or by using a separate form on our website. View form.
4.1 Access to your own information
It is important to us that all personal information is securely disclosed, without the risk of anyone other than you, the data subject, obtaining the information.
Disclosure of crossing data and images
We have processes to ensure that crossing data and images are only disclosed to the registered vehicle owner for the period during which the crossings were made.
Access to and disclosure of invoice information
Copy invoices will only be sent to the original recipient address. Remember that you can find your invoice in your online bank if you have an e-invoice agreement.
4.2 Complaining about our processing of personal data
Please let us know if you think we are not complying with the rules in the General Data Protection Regulation. You can do this by contacting our Data Protection Officer on personvern@fjellinjen.no.
You can also contact the Norwegian Data Protection Authority to complain about our processing. See Datatilsynet.no for more information on how to submit such a complaint.
5.1 The Norwegian Public Roads Administration
All identified toll crossings are forwarded to the Norwegian Public Roads Administration for pricing and onward transfer to those responsible for collecting tolls. Visit autopass.no and vegvesen.no for more information. Toll crossings made with a valid AutoPASS subscription are transferred to your AutoPASS subscription provider. Crossings that cannot be linked to a valid AutoPASS subscription are returned to Fjellinjen for collection.
5.2 External partner used to collect tolls from foreign-registered vehicles
Fjellinjen uses non-Norwegian suppliers to perform some tasks. External partners are engaged to collect toll charges from foreign-registered vehicles without a tag. This processing is regulated by agreement and covered by a separate data processor agreement, as well as documented security measures.
5.3 Official bodies
Fjellinjen may, at the request of bodies such as the police or tax authorities, hand over information about toll crossings and associated invoice information.
5.4 Service providers
Some work relating to collecting tolls and operating websites and self-service solutions is carried out by external suppliers. These providers process your personal data on behalf of Fjellinjen and are not allowed to use this information for their own purposes. To ensure that this happens, Fjellinjen enters into agreements that determine how the information is processed, and sets requirements for security, storage and deletion for all suppliers who process personal data on our behalf.
5.5 Transfer to third countries
Fjellinjen does not transfer personal data to, or use suppliers that process personal data in, or transfer personal data to, countries outside the EU/EEA.
Access to personal data is only given to people who need to access such data to do their work. Systems in which personal data is stored and processed are protected through access control with personal ID / password and necessary technical information security measures.
Collected personal data is stored for as long as we need the data to collect tolls and deal with complaints, manage the ICT system and prepare aggregated statistics for tolls, and to fulfil retention obligations according to the Norwegian Bookkeeping Act.
Toll crossing information is deleted in accordance with fixed criteria depending on whether or not the crossing has been paid for.
Fixed deletion deadlines:
Toll crossings:
Other enquiries:
Updated: 08.09.2023