Processing of personal data in the context of the City of Vantaa’s photography consent

When you take part in a photo shoot, you will need to sign the City of Vantaa photography consent. The City of Vantaa requires an agreement including photography consent when the photographs feature identifiable persons. 

The consent agreement requires the photo subjects to grant authorisation to use the photo materials in the way indicated in the consent. The consent to photography is necessary when the photo materials feature identifiable persons and the photos will be used across various City of Vantaa materials and channels. The photography consent only applies to photos to be included in the media bank. 

The consent grants the City of Vantaa the right to use the photos for the period of time indicated in the consent and to re-crop the photos after this to ensure that no persons in the photos can be identified.  

The City of Vantaa processes the information encompassed by the consent in conjunction with using the photos and to attach the photography consent to the photos. The consent information is displayed to users of the Vantaa media bank who have higher-level rights.  

Legal basis for the processing: 

• Article 6(1)(a) and (c) of the EU General Data Projection Regulation (2016/679)  

• Section 6 of the Data Protection Act (1020/2018) 

The consent form requests the relevant person’s name, telephone number, e-mail address and organisation. In the context of group photo shoots, identifying details may be requested (clothing or similar, for example). The consents to photography are stored either digitally in the City of Vantaa media bank or in the archive of the party that requested the consent. 

By participating in a photo shoot, you give the City of Vantaa permission to use the photographs. Personal details are required for the photography consent, so that we can attach the consent to the photos. As specified in the consent form, the photography consent authorises the use of the photos. The photography consent remains valid for five (5) years from the time of photography, unless otherwise agreed in the consent.  

Your personal data will not be disclosed to third parties outside the City of Vantaa, nor will the data be transferred to other systems or outside the EU or EEC area. 

In order to ensure your 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.  

The staff are under an obligation to secrecy and non-disclosure, which will remain in force after the employment and public service relationship.  

In cases where the processor of personal data processes the data on behalf of the City of Vantaa, the appropriate level of data security and data protection is agreed upon in the agreement made with the processor. The personal data processor is the party that processes personal data on behalf of the City (a service provider, for example).  

As a general rule, personal data may only be processed within the EU and EEC, but the processor may also transfer data outside the EU or EEC. However, such transfers are only permitted when they meet the requirements placed on them in the data protection legislation and the relevant agreement to ensure the sufficient protection of personal data. 

Despite the protection measures, in some exceptional cases it is possible for your personal data to be compromised by a data security breach or end up in the hands of a third party. In these cases, we will take immediate measures to rectify the situation and, if the breach causes a risk to you, we will notify the Data Protection Ombudsman. The notification will be sent no later than within 72 hours of gaining knowledge of the breach. If the data security breach causes a high risk, we will also notify you of the situation. 

Your data will be stored and destroyed in accordance with the City of Vantaa 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. After the storage period, the data will be destroyed.  

In accordance with the relevant level of access rights, the photography consent is displayed in the context of each photo in the Vantaa media bank for the period specified in the consent. After this, the consent and photo will be archived in the system. The photography consent grants the City of Vantaa the right to use the photos for the period of time indicated in the consent and to re-crop the photos after this to ensure that no persons in the photos can be identified. 

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

The term ‘data subject’ refers to the person whose personal data is being processed. 

If we process your personal data, you have the right to  

• check which details of yours are being processed, 

• request the rectification of erroneous or inaccurate information, 

• request the erasure of your personal data, 

• request the restriction of the data processing, and 

• 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 to request more information on personal data processing or your rights, please contact the person listed under the section ‘More information on data processing and contact persons.’ 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. If we intend to collect a fee on the completion of your request, we will contact you. 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 is 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 15 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) 

Street address: Ratapihantie 9, 00520 Helsinki, Finland 

Postal address: P.O. Box 800, 00521 Helsinki, Finland 

E-mail: tietosuoja(at)om.fi  

Telephone (exchange): +358 (0)29 566 6700 

Telephone (guidance for private persons): +358 (0)29 566 6777 

More information on the processing of personal data is available from the contact person specified below. Please note that e-mail is not a safe medium for processing personal data. As such, please do not send sensitive information, such as your personal identity code, via e-mail. 

Contact person 

viestinta@vantaa.fi 

The data controller is the City of Vantaa. 

Data protection officer 

tietosuojavastaava@vantaa.fi 

Registry office  

Postal address: P.O. Box 1100, 01030 City of Vantaa 

Street address: Tikkurila’s Vantaa Info, Dixi, Ratatie 11, 2nd floor, 01300 Vantaa, Finland. 

Telephone (exchange): +358 (0)9 839 11 

Fax +358 (0)9 8392 4163, e-mail: kirjaamo@vantaa.fi 

The information document was updated on 28 April 2022 

The City of Vantaa’s information documents have been collected and made available on the web page ‘Processing of personal data by the City of Vantaa.’