The Employment Fund carefully process personal data in accordance with the EU General Data Protection Regulation and other legislation that is applicable to the Employment Fund's operations and in force, as well as the authorities' instructions on processing of personal data.
Each register at the Employment Fund has a privacy policy, where you can find more information about the processing of personal data. The privacy policy includes the purpose and legal basis of the data processing, the categories of personal data and the period for which the data will be stored among other things.
Unemployment insurance contributions, restructuring protection fees, employer’s liability component, compensation pursuant to the Employment Contracts Act.
1. Controller
Employment Fund
P.O. Box 113
00181 Helsinki
2. Contact information regarding the data file
If you have any questions about data security matters, please contact the Employment Fund's data protection officer.
Data protection officer's contact information:
Email: tietosuoja@tyollisyysrahasto.fi
Tel.: +358 (0)9 6803 7380 (switchboard)
Postal address: Employment Fund, Data protection officer, P.O. Box 113, 00181 HELSINKI
Street address: Itämerenkatu 11 - 13, 00180 Helsinki
3. Purpose and legal basis of personal data processing
The operation of the Employment Fund is based on the Act (No. 555 of 1998) to finance unemployment benefits. Our duty is to impose and collect unemployment insurance contributions, restructuring protection fees and employers' liability components, and to supervise that the above obligations are fulfilled. Our further duty is, pursuant to chapter 12, section 3 of the Employment Contracts Act, to enforce contributions, and collect any related amount deductible from compensations that is payable to the Fund. Personal data processing is necessary in order to perform the Employment Fund's statutory duties and customer relationships (EU's General Data Protection Regulation, article 6, paragraph 1, subparagraph c).
Personal data in the data file may be used for the purposes of developing the Employment Fund’s services and operations, processing feedback, and for statistical purposes. Data collected from call recordings may be used for the purposes of verifying service transactions, develop customer service in the training of customer service personnel, and for service level assessments. (EU's General Data Protection Regulation, article 6, paragraph 1, subparagraph f).
4. Personal data categories to be processed
5. Regular sources of data
In order to deal with unemployment insurance contributions, restructuring protection fees, employers' liability components and compensations pursuant to the Employments Contract Act, we will have access to documents and any other information submitted to the Fund by yourself, your representative or agent. To impose, collect and supervise unemployment insurance contributions and restructuring protection fees, and to impose and collect employers' liability components, the Fund is able to access the national Incomes Register (KATRE). Information is also obtained from the Population Register and the Business Information System. The Fund also has access to information necessary for the performance of its duties from employers, the Tax Administration, the Finnish Centre for Pensions, pension and insurance institutions, Kela, unemployment funds, Ministry of Economic Affairs and Employment, KEHA Centre, and law courts.
We only request information that is necessary for us to do your work.
6. Storage period of personal data
We store your data for as long as necessary to fulfil our statutory duties, or as long as the law and regulations require.
The Employment Fund will keep an unemployment insurance register, containing personal data, in order to fulfil its statutory duties. Personal data in the unemployment insurance register will, as a rule, be stored for 5 years. However, in certain cases, documents must be stored for 10 years.
Documents and other information related to an employer’s liability component matters are stored 20 years from issuing the decision. Appeal documents must be stored for a minimum of 10 years, unless they have to be stored for a longer period of time due to the aforementioned or other reasons.
The documents necessary for the collection of unemployment insurance contributions, transition security contributions and liability components are stored until the end of the collection process and for five calendar years after that.
Documents and other information related to restructuring protection fees are stored for 10 years from the end of the calendar year following the decision.
Documents and other information related to compensation pursuant to the Employment Contract Act will be stored until 15 years have passed since the arrival of the first document in the case.
We retain recorded phone calls for two years.
7. Disclosure of personal data
We will disclose your data when another authority has the legal right to your data. We will disclose your personal data to, for example, the Tax Administration, Finnish Centre for Pensions, the Finnish Workers' Compensation Center, the Grey Economy Information Unit, appeal authorities and law courts. Moreover, to determine the amount of employer's liability components and compensation pursuant to the Employments Contract Act, the necessary personal data will be submitted to the employer in question. Personal data will also be disclosed to unemployment funds and TE offices.
Before disclosing any information, we will always check that the intended recipient is entitled to receive such information.
The Employment Fund also has external service providers to whom we disclose personal data. We only use service providers that fulfil the requirements of the EU General Data Protection Regulation and the national legislation concerning personal data processing. A GDPR-compliant agreement will be made with external service providers on personal data processing.
No data will be disclosed to a party outside the EU or EEA.
8. Automatic decisions
Provided certain conditions are met, the Employment Fund will issue automatic decisions on unemployment insurance contributions.
The Employment Fund will not engage in profiling.
9. Protection of personal data
The data security of the Employment Fund's personal data files and the confidentiality, integrity and usability of personal data is ensured with the appropriate technical and administrative measures. Data and the service is protected by means of, for example, firewalls, physical protection of data rooms, access control, user rights and encryption techniques, in addition to the above-mentioned active supervision. Personal data is protected from unauthorised access or illegally or accidentally occurring data processing. Manual material is stored in locked storage areas.
Personal data will only be processed by persons whose work duties authorise them to process such data and who work for the Employment Fund, and by third parties assigned by the Employment Fund to maintain or develop the services. Anyone processing personal data will log in to the systems with a personal user ID and password. The right to access the data file is restricted in the manner required by the job role. All of the people who use data on the file are bound by a non-disclosure agreement.
10. Rights of the data subject
The EU General Data Protection Regulation guarantees different rights to data subjects, i.e. the persons whose data are processed. It is possible to fulfil the rights in different ways depending on the basis of the personal data processing.
a) Right to access personal data
You have the right to access your personal data stored by the Employment Fund. However, your right to access your data may be restricted on the basis of legislation and other practices concerning privacy protection.
b) Right to have data corrected
You have the right to have your data corrected if it contains errors or is incomplete. Legislation may in some cases restrict your right to have corrections made.
c) Right to have data removed
You do not have the right to have your data removed inasmuch as your personal data is processed to fulfil the Fund's statutory obligations.
We also have a statutory obligation to store your data for a certain period.
d) Right to demand restricted processing
You do not have the right to restrict data processing inasmuch as your personal data is processed to fulfil the Fund's statutory obligations.
e) Right to transfer data from one system to another
You do not have the right to demand your data to be transferred from one system to another inasmuch as your personal data is processed to fulfil the Fund's statutory obligations.
f) Right to object to personal data processing
You do not have the right to object to processing of your data inasmuch as your personal data is processed to fulfil the Fund's statutory obligations.
You can make a request to access personal data or a request for rectification of personal data in accordance with the EU General Data Protection Regulation on the online service for unemployment insurance contributions. Making a request requires a customer ship with the unemployment insurance contribution services.
In principle, the information on the data subject is provided free of charge. If the request for information is clearly groundless and unreasonable, especially if requests for information are made repeatedly, the Fund can charge the administrative costs caused by providing the information or refuse to provide information at all. In such a case, the Fund demonstrates that the request is clearly groundless and unreasonable.
11. Right to amend the content of the privacy notice
As the Employment Fund is continuously developing its services, we reserve the right to amend the content of the privacy notice as processing activities change. We may also amend the privacy notice as the result of changes in legal requirements. We recommend that you regularly revisit the contents of our privacy notice.
12. Right to make an appeal to supervisory authority
You have the right to make an appeal to the Data Protection Ombudsman if you consider that the processing of your personal data is in breach of the EU's General Data Protection Regulation.
Contact information of the Data Protection Ombudsman:
https://tietosuoja.fi/en/contact-information
Processing of applications concerning adult education benefits and scholarships for qualified employees
1. Controller
Employment Fund
P.O. Box 113
00181 Helsinki
2. Contact information regarding the data file
If you have any questions about data security matters, please contact the Employment Fund's data protection officer.
Data protection officer's contact information:
Email: tietosuoja@tyollisyysrahasto.fi
Tel.: +358 (0)9 6803 7380 (switchboard)
Postal address: Employment Fund, Data protection officer, P.O. Box 113, 00181 Helsinki
Street address: Itämerenkatu 11 - 13, 00180 Helsinki
3. Purpose and legal basis of personal data processing
The operation of the Employment Fund is based on the Adult Education Assistance Act (Act 1276 of 2000). Personal data processing is necessary as part of the benefit service in order for the Employment Fund to perform its statutory obligations (EU's General Data Protection Regulation, article 6, section 1 c).
The benefit service processes personal data in the following situations:
Personal data in the data file may also be used for the purposes of developing the Employment Fund’s services and operations, processing feedback, and for statistical purposes. Data collected from call recordings may be used for the purposes of verifying service transactions, develop customer service in the training of customer service personnel, and for service level assessments. (EU's General Data Protection Regulation, article 6, section 1 f). You can withdraw your consent on the online service for adult student benefits.
4. Personal data categories to be processed
5. Regular sources of data
The Employment Fund request the necessary information for applications concerning adult education allowance and scholarships for qualified employees primarily from the applicants themselves.
The Fund also has the right to access information needed for benefit processing from the Finnish Centre for Pensions, Kela, insurance institutions, the Tax Administration, and the applicant's employer and educational institution. From 1 January 2020 onwards the Employment Fund obtains information also from the national Incomes Register.
The Fund will only request information that is necessary for benefit processing. If the applicant fails to submit the necessary information, the application cannot be processed.
6. Storage period of personal data
Pursuant to section 14 of the Adult Education Assistance Act, recipients of adult education allowance have the right to the maximum duration of the allowance once during their working career. The Employment Fund must, in making benefit decisions, whether the applicant has previously received adult education allowance and how much of any allowance period still remains. This is why the data retention period for the record of allowance recipients and granted allowance rights is 100 years.
Pursuant to section 2 of the Adult Education Assistance Act, a scholarship for qualified employees may be granted in the form of a lump sum for someone who has completed a degree specified in the Vocational Education and Training Act (Act 531 of 2017). In making a decision, the Employment Fund must ensure that a person has not previously been granted a scholarship on the basis of a degree that is the subject of the application. This is why the data retention period for the record of scholarship recipients and completed degrees is 100 years.
7. Disclosure of personal data
The Employment Fund will disclose data related to benefits to the Finnish Centre for Pensions, Kela, the Tax Administration and from 1 January 2020 onwards the national Incomes Register, and in other situations when another authority has the legal right to your data. The Fund also discloses information about benefit recipients to Statistics Finland for statistical purposes. If a benefit applicant is appealing against a decision, the Fund will also disclose information to the social security appeal committee (samu.fi) or Insurance Court, whichever is acting as the appeal authority.
Before disclosing any information, the Fund will always check that the party requesting the information is actually entitled to receive it. No data will be disclosed to a party outside the EU or EEA.
The Employment Fund also has external service providers to whom we disclose personal data. We only use service providers that fulfil the requirements of the EU General Data Protection Regulation and the national legislation concerning personal data processing. A GDPR-compliant agreement will be made with external service providers on personal data processing.
If the decision on benefits cannot be served on the applicant by standard or verifiable service, for example because the applicant's address is unknown or he avoids service, the Fund is under Administrative Procedure Act ultimately entitled to serve as a service by publication. Service by publication is effected by keeping the document available for the addressee on the premises of the authority for a specified period. A notice of the availability of the document shall be published on the fund's website and will include the client's full name, date of decision and application/decision number.
8. Automated decision-making
As of 1 August 2020, the Employment Fund can automatically process some benefit applications without an employee of the Fund actively participating in making the benefit decision. Automated decision-making is always based on the customer’s explicit consent. (EU General Data Protection Regulation, article 22, section 2 c). Consent will be asked about in the electronic communication service when applications are filed, and can be withdrawn your consent at any time on the online service for adult student benefits.
The staff of the Employment Fund will still manually process the applications of all customers that have not provided consent to automated decision-making, as well as all initial applications and other applications that are not suitable for automated processing.
The Employment Fund will not engage in profiling.
The Content Manager of the Employment Fund's adult education benefits service is responsible for the correctness of the decisions made automatically. Decisions on groups of applications to be processed automatically fall under the responsibility of the Service Manager in charge for the adult education benefit processes.
If you have any questions about automatic decisions, you can contact the Employment Fund’s Content Manager of adult education benefits: koulutusetuudet@tyolliyysrahasto.fi. In the subject line of the e-mail, type ”Question about automatic decision”. You can also call +358 (0)9 6803 7380 (switchboard). You can send mail to the Employment Fund, Benefits for Adult Students / Content Manager, P.O. Box 191, 00121 HELSINKI. The Employment Fund is located at Itämerenkatu 11 - 13, 00180 Helsinki.
9. Protection of personal data
The data file containing personal data can only be accessed by Employment Fund staff or a third party assigned by the Fund to maintain or develop the services, having a personal user ID and password and individually defined user rights. Any viewing or modification of data file content will result in a log entry. Data is stored in databases and storage systems separated with a firewall from the public network. Entry into the systems from the public network is arranged in a secure manner. Databases and their backups are stored in locked premises that can only be accessed by designated administrators. Any confidential information sent through the public network is encrypted in a way that fulfils data security requirements.
10. Rights of the data subject
The EU General Data Protection Regulation guarantees different rights to data subjects, i.e. the persons whose data are processed. It is possible to fulfil the rights in different ways depending on the basis of the personal data processing.
a) Right to access personal data
Employment Fund customers have the right to access their personal data stored by the Employment Fund. The Fund will send a customer a copy of their personal data processed by the Fund upon request.
b) Right to have data corrected
Employment Fund customers can demand any incorrect or insufficient personal data concerning themselves to be corrected.
c) Right to have data removed
An Employment Fund customer may require that information pertaining to them be deleted only to the extent that the retention of the information is not based on the Employment Fund’s compliance with its statutory obligations.
d) Right to demand restricted processing
The right of an Employment Fund customer to require the restriction of the processing of personal data is restricted by the Adult Education Assistance Act. However, the customer may exercise their right if they notice the Employment Fund processing or storing their personal data in violation of law but do not wish their data to be immediately removed.
e) Right to transfer data from one system to another
The Employment Fund processes personal data as part of its statutory obligations in the capacity of a controller. This is why customers cannot demand that their personal data be transferred to another system.
f) Right to object to personal data processing
Employment Fund customers cannot object to their personal data from being processed inasmuch as the Fund performs its statutory obligations.
You can make a request to access personal data or a request for rectification of personal data in accordance with the EU General Data Protection Regulation on the online service for adult student benefits. Making a request requires a customer ship with the adult student benefits.
In principle, the information on the data subject is provided free of charge. If the request for information is clearly groundless and unreasonable, especially if requests for information are made repeatedly, the Fund can charge the administrative costs caused by providing the information or refuse to provide information at all. In such a case, the Fund demonstrates that the request is clearly groundless and unreasonable.
11. Right to amend the content of the privacy notice
As the Employment Fund is continuously developing its services, we reserve the right to amend the content of the privacy notice as processing activities change. We may also amend the privacy notice as the result of changes in legal requirements. We recommend that you regularly revisit the contents of our privacy notice.
12. Right to make an appeal to the Data Protection Ombudsman
You have the right to make an appeal to the Data Protection Ombudsman if you consider that the processing of your personal data is in breach of the EU's General Data Protection Regulation.
Contact information of the Data Protection Ombudsman:
https://tietosuoja.fi/en/contact-information
Employment Fund
PO Box 113
00181 Helsinki, Finland
2. Contact details for matters concerning the register
If you have any questions about data protection, please contact the Employment Fund’s Data Protection Officer.
Contact details for the Data Protection Officer:
Email: tietosuoja@tyollisyysrahasto.fi
Tel: +358 9 6803 7380 (switchboard)
Postal address: Employment Fund, Data Protection Officer, PO Box 113, 00181 HELSINKI, Finland.
Visiting address: Itämerenkatu 11 - 13, 00180 Helsinki, Finland.
3. Purpose of processing personal data and legal basis
Information on job applicants is collected during targeted and open recruitment processes for the purpose of conducting recruitment and related measures, such as comparing applicants.
The processing of personal data is based on the implementation of agreements or the implementation of pre-contractual measures in accordance with Article 6 (1) (b) of the General EU Data Protection Regulation (2016/679).
4. Categories of personal data processed
5. Regular data sources
The primary source of the data stored on the file is the job applicant himself/herself. In addition, data is compiled from information saved during the hiring process. Other data sources are used within the limits provided by law.
6. Retention period for personal data
Personal data is retained for six months after the end of the recruitment process, taking into consideration the period for bringing legal action as defined in the law and the maximum retention period for applications.
Recruitment videos will be stored on RecRight for one (1) year.
7. Disclosure of personal data
The Employment Fund uses, if necessary, external service providers to process the data, e.g. the video service provider and the body conducting aptitude tests.
We only use service providers that fulfil the requirements of the EU General Data Protection Regulation and the national legislation concerning personal data processing. A GDPR-compliant agreement will be made with external service providers on personal data processing.
Personal data is not disclosed or transferred outside the EU or EEA.
8. Automatic decisions
The processing of your personal data does not include automatic decision-making.
9. Protection of personal data
The information security of the Employment Fund’s personal data file and the confidentiality, integrity and accessibility of personal data are assured using appropriate technical and administrative measures. The service and data are protected by means such as firewalls, protection of the physical hardware rooms, access management, user access rights and encryption, as well as via active monitoring of the foregoing. Personal data is protected from unauthorised access and unlawful or accidental data processing. Manual material is stored in locked storage areas.
Personal data is only processed by people who are authorised to process it in the course of their working duties and who are employed by the Employment Fund, as well as third parties commissioned by the Employment Fund to maintain or develop services. The people who process personal data are required to sign in to systems using personal user IDs and passwords. The right to access the data file is restricted in the manner required by the job role. All of the people who use data on the file are bound by a non-disclosure agreement.
10. Rights of data subjects
You are entitled to receive information about the data that the Employment Fund is holding on you, request that your data be corrected if data on you is incorrect or incomplete, and demand that your data be deleted.
You are also entitled to transfer data from one system to another. In other words, you are entitled to receive the personal data on you and transfer it to a different controller. In addition, you are entitled to request restrictions on the processing of personal data and object to the processing of personal data.
Requests to exercise the foregoing rights should be sent to the Data Protection Officer.
In principle, the information on the data subject is provided free of charge. If the request for information is clearly groundless and unreasonable, especially if requests for information are made repeatedly, the Fund can charge the administrative costs caused by providing the information or refuse to provide information at all. In such a case, the Fund demonstrates that the request is clearly groundless and unreasonable.
11. Right to file a complaint with the supervising authority
You are entitled to file a complaint with the supervising authority if you consider the EU General Data Protection Regulation to have been breached when personal data was processed.
Contact details for the Office of the Data Protection Ombudsman:
https://tietosuoja.fi/en/contact-information
1. Controller
Name: Employment Fund
Postal address: P.O. Box 113, 00181 Helsinki, Finland
Telephone: +358 (0)9 6803 7380 (switchboard)
Registry contact person
Managing Director, Janne Metsämäki
Postal address: P.O. Box 113, 00181 Helsinki, Finland
Email address: kirjaamo@tyollisyysrahasto.fi
Telephone: +358 (0)9 6803 7380 (switchboard)
2. Data Protection Officer
Data Protection Officer
Postal address: P.O. Box 113, 00181 Helsinki, Finland
Email address: tietosuoja@tyollisyysrahasto.fi
Telephone: +358 (0)9 6803 7380 (switchboard)
3. Purpose and legal basis for processing of personal data
Employment Fund processes personal data collected to the stakeholder work register so that it can comply with the obligation to report information to the Finnish Transparency Register. Lobbying activities targeting Parliament and ministries are reported to the Finnish Transparency Register.
In addition to reporting the information to the Finnish Transparency Register, we also use the information in our own stakeholder cooperation.
The personal data is processed on the basis of the legitimate interests pursued by the controller (Article 6(1)(f) of the General Data Protection Regulation of the EU).
4. Personal data processed for the stakeholder work register
The following personal data is processed for the stakeholder work register: Name, title, organisation/unit/department/group
5. Sources of personal data
Personal data is collected from public information sources (such as websites) and on the basis of bilateral contacts.
6. Disclosures, recipients and transfers of personal data
Employment Fund discloses the information listed in section 4 to the Finnish Transparency Register maintained by the National Audit Office of Finland in accordance with general timetables twice a year: lobbying activities carried out in January–June are disclosed in July–August, and the lobbying activities carried out in July–December are disclosed in January–February.
Individual persons are named if the lobbying has targeted Members of Parliament, ministers, State Secretaries and special advisers appointed for ministers’ terms of office, Secretary-General and Deputy Secretary-General of Parliament, ministries’ Permanent Secretaries, Permanent Under-Secretaries and heads of department, or rapporteurs appointed by ministries.
Other public officials are not separately named. For other public officials of the Parliamentary Office, name of the committee, department and unit, or other corresponding part of the organisation is given. For parliamentary assistants and parliamentary group personnel, the name of the parliamentary group is given. For ministries’ other public officials, the name of the department and unit is given.
In addition to personal details, the lobbying targets, reasons for the contacts and methods of contact are also given in the disclosure of operations.
Employment Fund uses external service providers in the processing of the personal data and is responsible for the activities of the service providers that it has selected when personal data is processed. System suppliers are used as service providers.
No personal data is transferred outside the EU or the EEA.
7. Automated decision-making and profiling
No automated decisions or profiling are made on the basis of the data.
8. Personal data storage period
Information concerning stakeholder cooperation is stored in Employment Fund for ten years.
9. Protection of personal data
Employment Fund processes personal data in a secure manner and in accordance with the legislation in force. Access to the stakeholder work register is restricted by means of access rights, and the persons involved in stakeholder cooperation are bound by a duty of professional secrecy.
Employment Fund has taken all appropriate technical and administrative measures to protect personal data against accidental or unlawful loss, disclosure, misuse, alteration, destruction or unauthorised access by using such means as the protection of hardware and files and access restrictions.
10. Rights of the data subject
The data subject has
• the right of access to their own personal data;
• the right to request the correction or supplementation of inaccurate or incomplete personal data on them;
• the right to request the erasure of personal data or restriction on the processing of personal data; and
• the right to object to the processing of personal data for a specific personal reason.
The data subject has the right to submit a complaint to the supervisory authority (in Finland, to the Data Protection Ombudsman) if the data subject considers that the data protection legislation has been violated in the processing of the personal data.
Contact details of the Data Protection Ombudsman: tietosuoja@om.fi, tel. +358 (0)29 566 6777, https://tietosuoja.fi/en/home
If you wish to exercise your rights, please contact the registry contact person mentioned in section 2 for further instructions.
1. Controller
Name: Employment Fund
Postal address: PO Box 113, 00181 Helsinki, Finland
Telephone: +358 (0)9 6803 7380 (switchboard)
2. Registry contact person
Compliance Officer
Postal address: PO Box 113, 00181 Helsinki, Finland
Email address: compliance@tyollisyysrahasto.fi
Telephone: +358 (0)9 6803 7380 (switchboard)
3. Data Protection Officer
Data Protection Officer
Postal address: PO Box 113, 00181 Helsinki, Finland
Email address: tietosuoja@tyollisyysrahasto.fi
Telephone: +358 (0)9 6803 7380 (switchboard)
4. Purpose and legal basis of the processing of personal data
The Employment Fund’s whistleblowing channel has been established as a channel in which one can report suspected wrongdoing concerning activities against the law or the Employment Fund’s Code of Conduct.
Processing of personal data is based on compliance with the statutory obligations of the Employment Fund, such as the Act on the Protection of Persons Reporting Infringements of European Union and National Law (Whistleblower Act) and the Securities Markets Act, the general interest of the Employment Fund in the performance of its statutory task and the legitimate interest of the Employment Fund in the processing of violations of the Code of Conduct.
5. Personal data processed under the whistleblowing scheme
Reports on wrongdoing can be submitted by employees of the Employment Fund and persons belonging to stakeholders. The reports may also contain personal data on persons other than the whistleblower. The reports can be submitted anonymously, in which case no personal data on the whistleblower will be processed.
Depending on the content of the report, the following personal data is processed under the scheme:
Personal data clearly irrelevant for the investigation of the case contained in the report are deleted without undue delay.
6. Sources of personal data
Personal data is primarily collected from the whistleblower. During the investigation, necessary personal data can also be obtained from the other information systems of the Employment Fund and from third parties.
7. Disclosures and recipients of personal data and transfers of personal data
Personal data may be disclosed to the authorities as permitted and obligated by the legislation in force.
The Employment Fund uses external service providers in the processing of the personal data and is responsible for the activities of the service providers that it has selected when personal data is processed. The following parties are used as service providers:
Personal data may be transferred outside the EU and the EEA. When personal data is transferred outside the EU and the EEA, the transfer takes place using the standard contractual clauses of the European Commission or other lawful transfer mechanisms.
8. Automated decision-making and profiling
No automated decisions or profiling are made on the basis of the data.
9. Storage period of personal data
Information received through the whistleblowing channel is stored as long as it is necessary for the investigation of the reports. However, the information is kept for a maximum of five years, unless the storing is necessary for the exercise of the rights or obligations laid down in the Whistleblower Act or elsewhere in the law or for the preparation, presentation or defence of a legal claim. Personal data that is not clearly relevant to the processing of the report is deleted without undue delay.
10. Protection of personal data
The Employment Fund processes personal data in a secure manner and in accordance with the legislation in force. Access to the reports is restricted by means of access rights, and the persons processing the reports are bound by a duty of professional secrecy.
The Employment Fund has taken all appropriate technical and administrative measures to protect personal data against accidental or unlawful loss, disclosure, misuse, alteration, destruction or unauthorised access by using such means as the protection of hardware and files and access restrictions.
11. Rights of the data subject
As a rule, the data subject has
The data subject’s right of access to the data can be restricted with regard to personal data reported under the Whistleblower Act if it is necessary and proportionate to ensure the investigation concerning the accuracy of the report and to protect the identity of the whistleblower. In such cases, the data subject has the right to be informed of the reasons for any restriction and to request that the data should be provided to the Data Protection Ombudsman in accordance with section 34, subsections 3 and 4 of the Data Protection Act.
With regard to the reports submitted under the Whistleblower Act, the data subject does not have the right to restrict the processing of their personal data.
The data subject has the right to submit a complaint to the supervisory authority (in Finland, with the Data Protection Ombudsman) if the data subject considers that the data protection legislation has been violated in the processing of the personal data. Contact details of the Data Protection Ombudsman: tietosuoja@om.fi, tel. +358 (0)29 566 6777, Home | Data Protection Ombudsman’s Office (tietosuoja.fi)
If you wish to exercise your rights, please contact the registry contact person mentioned in section 2 for further instructions.
Updated 7 October 2024
Name: Employment Fund
Postal address: P.O. Box 113, 00181 Helsinki, Finland
Telephone: +358 (0)9 6803 7380 (switchboard)
Compliance Officer
Postal address: P.O. Box 113, 00181 Helsinki, Finland
Email address: compliance@tyollisyysrahasto.fi
Telephone: +358 (0)9 6803 7380 (switchboard)
Data Protection Officer
Postal address: P.O. Box 113, 00181 Helsinki, Finland
Email address: tietosuoja@tyollisyysrahasto.fi
Telephone: +358 (0)9 6803 7380 (switchboard)
The registry is kept of the Employment Fund’s managers referred to in the Market Abuse Regulation (hereafter also the ‘MAR Regulation’), their related parties and transactions, other insiders closely associated with the controller, scope of the trading restriction as well as the related parties and related party transactions specified in Employment Fund’s related party guidelines. Processing of the personal data is based on the statutory obligations of Employment Fund, such as compliance with the MAR Regulation, Securities Market Act and the Accounting Act. Employment Fund or the parties acting on its behalf or for its account have an obligation to keep a list of the persons who have access to inside information and who work for the controller on a contractual basis or who otherwise perform tasks giving them access to inside information.
The purpose of the processing of the personal data on the managers and their related parties is to ensure compliance with regulation concerning the transactions performed by the managers and their related parties specified in Article 19 of the MAR Regulation as well as compliance with the other acts, rules, regulations, guidelines and instructions binding on the controller.
All persons with access to inside information concerning a project and who work for Employment Fund or perform tasks for Employment Fund giving them access to inside information are entered in the project-specific list of insiders. The purpose of the processing of the personal data is to ensure compliance with regulation concerning the transactions carried out by these persons in accordance with Article 18 of the MAR Regulation as well as compliance with the other acts, rules, regulations, guidelines and instructions binding on the controller.
Employment Fund keeps a list of related parties specified in the related party guidelines based on the Accounting Act and the IFRS standard (IAS 24) to identify related party transactions and to comply with insider regulations.
The information concerning the preparation of financial reviews is highly confidential and for this reason, a list is kept of the persons taking part in the preparation of the financial reviews. The trading restriction referred to in section 2.3.2 of the insider guidelines of the Helsinki Stock Exchange applies to these persons for the duration of the closed period.
Employment Fund keeps a list of the persons with managerial responsibilities and their related parties. Members of the Supervisory Board and the Board of Directors, Managing Director and the Chief Financial Officer are considered as the persons with managerial responsibilities who and whose related parties must report their own financial transactions.
The following personal data on managers and their related parties is processed:
All persons with access to inside information concerning a project and who work for Employment Fund or perform tasks for Employment Fund giving them access to inside information are entered in the project-specific list of insiders.
The list of insiders contains the following details of the persons considered as insiders:
The following information on the related parties specified in Employment Fund’s related party guidelines (members and deputy members of the Board of Directors and the Supervisory Board, Managing Director, Deputy Managing Director and the members of the Management Group as well as the family member or other close relative of the above persons or the organisation controlled by them):
The personal data on the persons with managerial responsibilities and their related parties is collected under the MAR Regulation from the persons with managerial responsibilities and/or their related parties/related party contact persons, any parties that they have authorised and from public information sources (such as the Trade Register).
In accordance with the MAR Regulation, the information entered in the list of insiders is collected from the data subjects in connection with the submitting of the insider notification on a separate form completed by the data subject and, if necessary, also from public information sources (such as the Trade Register and BIS).
The data subjects must notify Employment Fund of their own transactions.
Employment Fund specifies the related parties on the basis of the related party guidelines and collects any additional information required for the purpose from the members of the Board of Directors and the Supervisory Board, Managing Director, Deputy Managing Director and the members of the Management Group.
Employment Fund specifies the persons that may access Employment Fund’s financial data and collects any additional information required for the purpose from the persons in question.
Personal data may be disclosed to parties that within the constraints and obligations specified in the legislation in force at the time have the right to access the data or if preparing, presenting or defending a legal claim requires the disclosure of personal data. For example, personal data can be disclosed to the parties named in the MAR Regulation and the rules issued under it, such as the FIN-FSA, ESMA (European Securities and Markets Authority) and the police.
Personal data may be transferred outside the EU and the EEA. When personal data is transferred outside the EU and the EEA, the transfer takes place using the standard contractual clauses of the European Commission or other lawful transfer mechanisms.
No automated decisions or profiling are made on the basis of the data.
The personal data storage period is determined in accordance with the requirements specified in the MAR Regulation, and other applicable corporate law provisions and securities market legislation. As a rule, the personal data is kept for five years from the registration of the personal data or its latest update. The data specified in the Accounting Act must be kept for ten years from the end of the financial year.
Employment Fund processes personal data in a secure manner and in accordance with the legislation in force. Employment Fund has taken all appropriate technical and administrative measures to protect personal data against accidental or unlawful loss, disclosure, misuse, alteration, destruction or unauthorised access by using such means as the protection of hardware and files and access restrictions.
Access to the register is restricted by means of access rights so that the data stored in the system can only be accessed and used by employees who have the right to do so due to their duties and who need the data in their tasks.
As a rule, the data subject has
The data subject has the right to request the erasure of their personal data (the right to be forgotten) when the data is no longer needed for the purposes for which it was collected or otherwise processed or when there are no statutory obligations to process or store the data.
The data subject has the right to submit a complaint to the supervisory authority (in Finland, to the Data Protection Ombudsman) if the data subject considers that the data protection legislation has been violated in the processing of the personal data.
Contact details of the Data Protection Ombudsman: tietosuoja@om.fi, tel. +358 (0)29 566 6777, https://tietosuoja.fi/en/home.If you wish to exercise your rights, please contact the registry contact person mentioned in section 2 for further instructions.
Employment Fund Data protection officer
P.O. Box 113, 00181 Helsinki
tietosuoja@tyollisyysrahasto.fi
Tel. 09 680 373 80 (switchboard)
The Employment Fund maintains and publishes a document publicity description based on section 28 of the Act on Information Management in Public Administration (906/2019, “Information Management Act”), the purpose of which is to
The document publicity description has been updated on 20th of September 2024.
The case register is a register of pending cases, their processing stages and documents. The Employment Fund case register consists of the following case registers:
Administrative case register
Description: Matters that are essential for the operation of the Employment Fund, such as complaints and requests for evidence received by the Employment Fund, requests for information, requests for statements, procurement contracts and requests for appointment, are recorded in the Employment Fund’s administrative case register. Administrative matters are given a unique case identifier.
Case register of unemployment insurance contributions
Description: Documents concerning the imposition, collection and supervision of unemployment insurance contributions, such as decisions, invoices and customer messages, are registered in the case register of unemployment insurance contributions.
Case register of the terminating employer’s restructuring protection fees
Description: For the purpose of imposing a restructuring protection fee, the relevant documents, such as hearing letters, decisions, information retrieved from the national incomes register and filing notifications by the unemployment fund or the Social Insurance Institution of Finland, and customer messages, are registered in the Employment Fund’s case register.
Case register of the employer’s liability component
Description: For the purpose of imposing a liability component, the relevant documents, such as hearing letters, decisions and customer messages, are registered in the Employment Fund’s case register.
Reduction in unemployment cover in connection with disputes concerning the termination of an employment relationship
Description: For the implementation of disputes concerning the termination of an employment relationship and reconciliation in accordance with the Employment Contracts Act , the Employment Fund’s case register contains documents concerning the end of employment dispute, such as court judgments or decisions, statements to courts, requests for agreement comments and final agreements as well as customer messages.
Case register of adult education benefits
Description: Documents concerning the granting, payment and collection of adult education benefits, such as decisions, applications, hearing letters, information retrieved from the national incomes register, filing notifications by the Social Insurance Institution of Finland and customer messages, are registered in the case register of adult education benefits.
Data repositories consist of extensive data sets that are logically or physically connected. The Employment Fund’s data repositories include:
Data sets consists of documents and other information related to a particular service or task. The data sets in the data repositories consist of, for example, the following information:
The following search criteria may be used to search for data in data repositories and case registers:
The Employment Fund’s information systems include:
You may submit a request for information on a document to the Employment Fund in the following ways:
Find our contact information by service here.
We will process requests for information under the Act on the Openness of Government Activities without delay, at the latest within two weeks of the request. If the request for information is extensive and requires more work than usual, the response time may not exceed one month. If the Employment Fund does not provide the requested information, the requestor will receive a written decision prepared by the Employment Fund, which will allow the requestor to lodge an appeal.
Section 22f of the Employment Fund Act (Act on the Financing of Unemployment Benefits 555/1998, “Financing Act”) contains a special provision on the application of the Act on the Openness of Government Activities (621/1999, “Openness Act”) to operations laid down in the Financing Act. The Openness Act applies to the operations of the Employment Fund to the extent that the Employment Fund exercises public authority (section 4, subsection 2 of the Openness Act) Information may be public, partly confidential and confidential. Confidentiality is always based on legislation, such as the secrecy clause of the Openness Act (section 24 of the Openness Act). The Financing Act also contains special provisions on secrecy (section 22f of the Financing Act).
For more information on requests for information under the EU’s General Data Protection Regulation (2016/679), see sections above.
