Recording customer calls in the City of Vantaa’s Employment Services and Services for International Customers

Personal data is processed for the verification of a customer service event, for the promotion of legal protection, for the promotion of security concerning the customer service situation, for ensuring the quality of customer service, and for the development of services.  

We will never use the data for other purposes such as direct marketing or commercial purposes.

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; GDPR Article 6(1)(e). Processing is necessary and proportionate in the activities of the authority in order to carry out a task in the public interest (Section 4(1) of the data protection Act. 2k*

The recording of calls is related to the performance of the statutory tasks of the employment authority and the integration authority, such as the implementation of the information and counselling service referred to in section 50 of the Act on the Organization of Employment Services (380/2023) by telephone.

Legal basis of processing:
The EU's General Data Protection Regulation (2016/679), Article 6(1)(a). 
The Data protection Act (2018/1050), section 4(1). 2k*

We record incoming and returned calls to the customer service numbers mentioned above. A human voice is stored as personal data if a person can be identified from it. The phone record saves a conversation that has taken place, which may contain different kinds of personal data. In addition, the phone number of the caller, the date and time of the call, and the duration of the call are recorded. The Suomi.fi strong authentication, if used, will give us the name and personal identity number of the person contacting us.

The provision of personal data is necessary and proportionate in the activities of the public authority for the performance of a public interest task, as provided for in Section 4(1)(2) of the Data Protection Act.

We will only disclose your personal data to another party if the data transfer is based on law or if you have given your consent to the disclosure of your data. You can cancel your consent to the disclosure of your data to outside parties at any time. The data will not be disclosed to outside parties for other purposes such as direct marketing or commercial purposes.

To ensure your privacy, we have protected your personal data with the help of various technological and organizational measures. For example, only the employees that need the data to perform their work are allowed to handle the data and only to the extent required by any individual task. In the customer-information system, this is monitored with the help of logfiles, among other things.

The employees are bound by confidentiality and professional secrecy, which continues also after termination of employment.

In cases where a party processes personal data on behalf of the City of Vantaa, the level of appropriate information security and data protection has been agreed on in the contract made with the processor. The processor of personal data refers to a party that processes personal data on behalf of the City of Vantaa, for example, a service provider.

As a general rule, data is processed only within the EU or EEA, but the processor may also transfer data outside the EU or EEA countries. Nevertheless, transfer is only allowed when it meets the demands of the data protection legislation and contract that ensure a sufficient level of protection of personal data.

Data will not be transferred outside the European Union (EU) area or the European Economic Area (EEA). 

It is possible that, regardless of protection, your personal data may exceptionally end up as a target of a breach of data, as well as in the possession of an outside party. In these cases, we will take immediate measures to rectify the situation and we will inform the data protection ombudsman if the breach of data security causes any risk to you. The notification will be made, at the latest, within 72 hours of noticing the breach of data security. If the breach of data security presents a high risk, we will also inform you about it.

Data will be stored and deleted in accordance with the City of Vantaa’s information management plan. The duration of storing documents specified in the information management plan is based on legislation, the National Archives of Finland's regulations for permanently stored documents, as well as the Association of Finnish Local and Regional Authorities’ recommendations for temporarily stored documents. After the end of the data storage period, the data will be deleted.

Storage periods:

• Call recordings: Six (6) months (180 days). The recordings are automatically deleted from the system after six months. By way of exception, the telephone record may be kept for a longer period if necessary for the purpose of clarification of the matter and legal protection. Upon completion of the investigation and the interest in legal protection, the recording will be deleted without delay.
• phone records: two (2) years (732 days).

Your data will not be used for profiling or automatic decision-making.

The data subject refers to the person whose personal data is being processed. If we process your personal data, you have the right to

• check how your data is processed
• demand that inaccurate or faulty data be corrected
• demand that your data be removed
• request that handling of your data be restricted
• object to handling of your data

You can submit a personal data inspection request through the e-service, in person at Vantaa-Info, or by mailing the inspection request to the City of Vantaa’s Registry. You can find more detailed instructions on the city’s Data Protection webpage.

If you wish to exercise the registered person's other rights or ask for additional information on the processing of personal data, please contact the person mentioned below in section 14. We will case-specifically verify the preconditions for exercising your rights. Exercising your rights may require verification of your identity.

We will execute information requests without undue delay, but, at the latest, within a month of receiving the request. The deadline can be extended by at most two months, when required, by accounting for the complexity and amount of data of the request. If the deadline is extended, we will inform you about it.

As a general rule, exercising your rights is free of charge. We may, however, charge a reasonable fee, corresponding with the administrative costs, for implementing the request, or decline to perform the measure, if the request is obviously ungrounded, unreasonable, or recurrent. If there is a charge for executing your request, we will contact you. If we decline to perform the measure, we will inform you in writing about the grounds for the refusal, as well as about the option to submit the matter to be handled by the data protection ombudsman, or to exercise other legal remedies.

If you suspect that your personal data is being illegally processed, you can submit an appeal to the data protection ombudsman. Further information on and instructions for submitting an appeal is provided by the contact person mentioned in section 14, the city's data protection officer, the data protection ombudsman's office website, and phone consultation:

Data protection ombudsman's office / www.tietosuoja.fi
Street address: Lintulahdenkuja 4, 00530 Helsinki
Mailing address: P.O. Box 800, 00531 Helsinki
Email: tietosuoja(at)om.fi 
Phone (switchboard): 029 566 6700
Phone (consultation for private persons): 029 566 6777

Additional information on processing personal data is provided by the contact person below. Please note that email is not a safe medium for processing personal data. Be sure not to send, for example, your identity number or any sensitive information by email.

The data controller is the City of Vantaa's Director of Employment and Integration Services. You will find the contact information of the data controller and the City of Vantaa's data protection officer below:

Controller

The City of Vantaa                     
Director of Employment and Integration Services                
Business ID: 0124610–9          
Asematie 7, 01300 Vantaa

Contact person of the data controller
tietosuoja-tyko@vantaa.fi

tel. 040 357 8120 / call recording matters in the Telia ACE telephone system       

Data protection officer

tietosuojavastaava@vantaa.fi

Registry

Mailing address: PL 1100, 01030 Vantaan kaupunki
Street address: Tikkurila Vantaa-info, Dixi, Ratatie 11, 2nd floor, 01300 Vantaa.
Phone (switchboard): 09 839 11
Fax: 09 8392 4163, email: kirjaamo(at)vantaa.fi