Processing of personal data in pupil and student welfare

The processing of personal data necessary for organising pupil and student welfare is based on statutory obligation. Some data is processed based on consent. Granting consent is voluntary and can be revoked at any time.

Legal basis for the processing

• Article 6(1)(a) and (c) of the EU General Data Protection Regulation (2016/679)
• Section 6 of the Data Protection Act (1020/2018)
• Pupil and Student Welfare Act (1287/2013)

For example, the names, personal identity codes and contact details of the students and their guardians are required for organising pupil and student welfare. The City of Vantaa primarily obtains the necessary information from the Digital and Population Data Services Agency (DVV) and the child’s guardians. Other information and documents concerning the student, such as a student welfare report recording the information necessary for organising and implementing multidisciplinary individual study welfare, also accumulate in the course of organising pupil and student welfare. Student welfare reports prepared in multidisciplinary individual student welfare services by the educational institution and the expressions of the student’s and their legal representative’s will, such as consents, are stored in the student welfare register.

Yes. Pupil and student welfare cannot be accessed without personal data, which means that the details are necessary for arranging the service.

The City of Vantaa may disclose your or your child’s data only with your consent or if required by law. For example, parties participating in the organisation and implementation of the student’s individual pupil and student welfare have the right to disclose to each other the information necessary for the organisation of pupil and student welfare. Information stored on the student welfare register may be disclosed via a technical access connection to a party entitled to access the information. The data will never be disclosed to third parties for marketing or other commercial purposes.

In order to ensure the student’s privacy, data security and data protection have been secured by means of various technical and organisational measures. For example, personal data may only be processed by persons who require the data for completing their work-related or public service tasks and only to the extent required on a task-specific basis. In the client data system, this is monitored, among other things, by using log information. Paper documents are kept in city archives in a safe place that no outsider can access. Staff are bound by the obligation of professional confidentiality and will continue to be bound by it after the end of their employment.

In cases where the processor of personal data handles personal data on behalf of the City of Vantaa, the appropriate level of data security and data protection has been agreed to in an agreement with the processor. As a rule, data is only processed in the EU or EEA area, but the processor can also transfer data outside the EU or EEA. However, the transfer is only permitted if it meets the requirements set out in the data protection legislation and the agreement, which ensure an adequate level of protection of personal data.

Despite the protection measures, in some exceptional cases it is possible for personal data to be compromised by a data security breach or end up in the hands of a third party. In these cases, the City of Vantaa will take immediate action to rectify the situation and submit the necessary reports to the national Data Protection Ombudsman and the data subjects affected. The City of Vantaa will notify the Data Protection Ombudsman of any breach without undue delay and, where possible, within 72 hours of becoming aware of the breach, unless the breach is unlikely to risk the rights and freedoms of any data subjects.

If the breach is likely to cause a high risk with regard to the data subjects’ rights and freedoms, the City of Vantaa will notify the data subjects of the breach without undue delay. In this case, the city will report the breach to those data subjects whose data is affected by the data security breach. If the data breach concerns a large group of people and does not require any immediate action from registered parties, the details of the data breach can also be provided as a general notification.

The data is stored and destroyed in accordance with the City of Vantaa’s data management plan. The document storage periods specified in the data management plan are based on legislation, the regulations of the National Archives of Finland on documents intended for permanent storage and the recommendations of the Association of Finnish Local and Regional Authorities on documents to be stored for a fixed period. At the end of the period, the data is destroyed. The retention periods for pupil and student welfare documents vary, with some data retained permanently.

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

The term ‘data subject’ refers to the natural person whose personal data is being processed. Depending on the basis for the processing, the registered party has the right to

• check the information processed by the application
• request the rectification of erroneous or inaccurate information
• request the erasure of personal data
• request the restriction of the data processing
• object to the processing of the data
• right to obtain the data and transfer it to another data controller, and to withdraw their consent at any time, if the processing is based on consent.

You can submit an access request via a separate form available through the vantaa.fi website and Vantaa Info desks. Should you wish to exercise other rights of a data subject or request additional information on the processing of personal data, please contact the person listed below in Section 15. The statutory requirements regarding exercising your rights will be confirmed on a case-by-case basis. Exercising your rights may require you to verify your identity.

The City of Vantaa will complete the requested measures without undue delay, but in any case no later than within a month of receiving the request. If necessary, the deadline may be postponed by a maximum of two months, based on the complexity and quantity of the requests. In the event that the deadline is postponed, the City of Vantaa will provide notification of the delay and the relevant grounds to the requesting party within one month of receiving the request.

The exercise of the rights is, in principle, free of charge. However, the City of Vantaa may collect a reasonable fee corresponding to the administrative costs for fulfilling a request or refuse a request if the data subject’s requests are clearly unfounded, unreasonable or recurring. If the intention is to collect a fee for fulfilling a request, the City of Vantaa will contact the person who submitted the request before fulfilment. In the event that the City of Vantaa refuses to fulfil the requested measure, the person who submitted the request will be provided with the grounds for the refusal in writing and informed of the opportunity to refer the matter to the Data Protection Ombudsman and resort to other legal remedies.

If you suspect that your personal details are being processed unlawfully, you can appeal to a supervisory authority in the EU member state of your permanent residence or employment or the member state where you consider the violation to have taken place. In Finland, the relevant supervisory authority is the Data Protection Ombudsman. More information and instructions for filing a complaint are available on the data protection ombudsman website and helpline:

Office of the Data Protection Ombudsman/www.tietosuoja.fi

Street address: Lintulahdenkuja 4, FI-00530 Helsinki Postal address: PO Box 800, FI-00531 Helsinki

Tel. (exchange): +358 29 566 6700

Telephone (helpline for private individuals): +358 29 566 6777

More information on the processing of personal data is available from the contact person specified 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.

Education and Learning Department, City of Vantaa

Tiina Kulju-Palo, Senior Specialist in Pupil and Student Welfare

Silkkitehtaantie 5 C, FI-01030 Vantaa

tiina.kulju-palo@vantaa.fi

+358 40 513 7818

The controller is the City of Vantaa’s Education and Learning Committee. Contact details of the controller and the City of Vantaa data protection officer can be found below:

Controller

City of Vantaa

Education and Learning Committee

Business ID 0124610-9

Data protection officer

tietosuojavastaava@vantaa.fi

Tel. +358 40 071 3358

Registry office

Postal address: PL 1100, FI-01030 Vantaan kaupunki

Street address: Vantaa Info Centre Tikkurila, Dixi, Ratatie 11, 2nd floor, FI-01300 Vantaa.

Tel. (exchange): +358 9 839 11

Fax +358 9 8392 4163

Email: kirjaamo(at)vantaa.fi