Processing personal data within Vantaa Employment Services acquired from Live Foundation

Job search coaching is a service where the purpose of the processing of personal data is to promote the employment of unemployed Vantaa residents as described below. According to Section 18(2) of the Constitution of Finland (731/1999), a public authority must promote employment and strive to ensure the right to work for everyone. The service is used to implement the aforementioned legal obligation/objective set for the municipality.

The purpose of the service is to help and motivate the clients participating in the service to actively seek work and employment in such a way that they:

• receive help in preparing for job interviews 
• have up-to-date job application documents, CV and applications 
• know the job search channels 
• are able to identify, describe and market their skills 
• are also able to apply for jobs effectively using electronic job search channels and online services. 

It is possible to provide the service to the clients of Vantaa Employment Services in place of complementary job search discussions under Section 10(3) of Chapter 2 of the Act on Public Employment and Business Service (916/2012).

In addition, personal data are used for service-related control, development, monitoring, compilation of statistics, forecasting and guidance.

Personal data will not be used for other purposes, such as direct marketing or commercial purposes.

The processing of personal data necessary for the organisation of the job search coaching service is based on the legal obligation of the City of Vantaa to promote employment and strive to ensure the right to work for everyone. Under Chapter 2, Section 10(3) of the Act on Public Employment and Business Service (916/2012), it is possible to provide job search coaching services to clients in place of complementary job search discussions. The processing of personal data is also necessary and proportionate for the performance of a task carried out in the public interest by an authority.

Legal basis for data processing:

• Article 6(1)(c) of the EU General Data Protection Regulation (679/2016): processing is necessary for compliance with a legal obligation to which the controller is subject. 
• Article 6(1)(e) of the EU General Data Protection Regulation (679/2016): processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 
• Section 4(1)(2) of the Data Protection Act (1020/2018): processing is necessary and proportionate for the performance of a task carried out in the public interest by an authority. 

Key legislation:

• EU General Data Protection Regulation (679/2016) 
• Data Protection Act (1050/2018) 
• Constitution of Finland (731/1999) 
• Act on Public Employment and Business Service (916/2012) 
• Act on Local Government Pilots on Promoting Employment (1269/2020) 
• Local Government Act (410/2015)

Data collected about the person participating in the service include:

• name 
• personal identity code 
• municipality of residence 
• phone number 
• email address 
• other contact information of the client 
• Proposal by the job search coach (Live Foundation) to the client participating in the coaching and to their designated coach in Employment Services for a possible further path (further service) of the client. 

The data are obtained from the client (data subject) themselves. Health data are not processed in the service. 

The service provider (Live Foundation) reports to the City of Vantaa on the provision of the service and conveys anonymous customer feedback for the assessment of the effectiveness of the service and for the development of the service. The reporting data do not contain personal data.

Yes. Without the client’s personal data, it is practically impossible to provide the job search coaching service. The amount of data collected and the processing measures are estimated to be proportionate to the objective pursued.

The City of Vantaa may disclose your data only if the disclosure is based on the legislation or if you have given your consent for the disclosure of your data. The data will never be disclosed to third parties for marketing or other commercial purposes. Live Foundation processes personal data in the job search coaching service on behalf of the City of Vantaa.

Data security and data protection have been secured in the City of Vantaa by various technical and organisational measures to ensure privacy. The equipment and software maintained by the City of Vantaa are protected with technical measures.

Personal data may be processed only by persons who need the data to perform their work or official duties and only to the extent required by an individual task. The processing of personal data is monitored by log information. The personnel must complete the information security and data protection training required by the city, and they are bound by the obligation to maintain secrecy and obligation of confidentiality that continue even after the end of employment.

As the data controller, the City of Vantaa requires Live Foundation to comply with the data protection and data security regulations of the City of Vantaa in the processing of personal data as the service provider.

The City of Vantaa only uses personal data processors that provide sufficient guarantees for the implementation of appropriate technical and organisational measures so that the processing meets the requirements of the EU General Data Protection Regulation and ensures the protection of the rights of the data subjects.

In the job search coaching service, personal data are not transferred outside of the EU or EEA.

Despite the protection measures, it is possible in exceptional cases that your personal data may be subject to a security breach or end up in the hands of a third party. In these cases, we will take immediate measures to rectify the situation. If the breach causes a risk to you, we will notify the Data Protection Ombudsman. The notification shall be made no later than 72 hours after discovering the breach. If the security breach poses a high risk, we will also notify you of the security breach. The service provider (Live Foundation) shall notify the City of Vantaa in writing of a personal data breach without undue delay and no later than within 36 hours of becoming aware of it.

The data are kept and destroyed in accordance with the City of Vantaa’s information management plan. 

The storing times of documents determined in the information management plan are based on legislation, the National Archives of Finland’s provisions concerning permanently stored documents and the Association of Finnish Municipalities’ recommendations concerning documents stored for a definite period of time. At the end of the period, the data will be destroyed. 

The data are stored in the job search coaching service for five (5) years starting from the year the customer relationship ended.

The data of data subjects will not be used for profiling or automatic decision-making.

Data subject means the person whose personal data are being processed. When we process your personal data in the job search coaching service, you have the right to:

• check what data of yours are being processed 
• demand the correction of incorrect or inaccurate data 
• demand the removal of your data 
• demand the restriction of the processing of your data 
• object to the processing of your data. 

You can submit an access request via a separate form available through the vantaa.fi website and Vantaa Info desks. If you would like more information about the processing of personal data or your rights, please contact the contact person listed in section 14 below. The statutory requirements regarding exercising your rights will be confirmed on a case-by-case basis once your identity has been verified.

We will fulfil the requests without undue delay, but in any case, no later than within one month of receiving each request. If necessary, the deadline may be postponed by a maximum of two months based on the complexity of the request and the quantity of the information. If the deadline is postponed, you will be notified.

As a general rule, exercising one’s rights is free of charge. However, we may collect a reasonable fee corresponding to the administrative costs or refuse a request if the request in question is clearly unfounded, unreasonable or recurring.

We will contact you if we intend to collect a fee for completing your request. If we refuse to complete your requested measure, you will be informed in writing of the grounds for the refusal and your right to refer the matter to the Data Protection Ombudsman or resort to other legal remedies. 

If you suspect that your personal data are being processed unlawfully, you can submit an appeal to the Data Protection Ombudsman.  More information and instructions on submitting an appeal are available from the contact person specified in section 14, the city’s data protection officer and on the website of the Office of the Data Protection Ombudsman and the office’s telephone guidance service:

Office of the Data Protection Ombudsman/www.tietosuoja.fi 
Visiting address: Lintulahdenkuja 4, 00520 Helsinki 
Postal address: PO Box 800, FI-00521 Helsinki 
Email: tietosuoja(at)om.fi  
Tel. (exchange): +358 29 566 6700 
Telephone guidance for private persons: +358 (0)29 56 66777

For more information on the processing of personal data, please contact the contact person listed below. Please note that email is not a safe medium for processing personal data. As such, please do not send sensitive information, such as your personal identity code, via email:

Contact person:

• Saara Nykänen, Coordinator/Data Protection Officer for Employment Services, City Strategy and Management Department, Service Area of Employment and Integration, firstname.lastname(at)vantaa.fi, tel. +358 40 650 3095
• Janne Riipinen, Lawyer, Urban Strategy and Management, Employment and Integration Service Area, firstname.lastname(at)vantaa.fi, tel. +358 40 500 2745

The controller is the City of Vantaa, the City Board (Section 1 of Chapter 8 of the Administrative Regulations of the City of Vantaa).  
Contact details of the controller and the City of Vantaa data protection officer can be found below:

Controller

City of Vantaa 
City Board 
Business ID 0124610-9  
Asematie 7, 01300 Vantaa 

Data protection officer

tietosuojavastaava@vantaa.fi

Registry office of Vantaa

Postal address: P.O. Box 1100, 01030 City of Vantaa
Address: Ratatie 11, Vantaa-info, 2. floor, 01300 Vantaa.
Phone: +358 9 83911
Fax 09 8392 4163, Email: kirjaamo(at)vantaa.fi