Processing of personal data in pre-primary education

The processing of personal data necessary for organising pre-primary education is based on statutory obligation. The child’s photos, videos and work are processed with the consent of the child’s guardian and only in the manner specified therein. The consent will be requested in writing with a separate photographing, videoing and publishing permission. 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)

For example, the names, personal identity codes and contact details of the child and their guardians are required for organising pre-primary education. The City of Vantaa primarily obtains the necessary information from the Digital and Population Data Services Agency (DVV) and the child’s guardians. Subject to conditions provided by law, the City of Vantaa may also request information necessary for organising pre-primary education from other authorities, such as the early childhood education and care organiser or the child’s previous pre-primary education place.

Yes. Organising pre-primary education requires receiving the necessary information requested in the application from the family and processing the data accrued in the course of education (e.g. LEOPS).

The City of Vantaa may disclose your or your child’s data with your consent or if required by law. For example, if the child changes pre-primary education place or moves to basic education, the information necessary for organising education may be disclosed to the education provider in the manner prescribed by law. The necessary information is also disclosed for the Wellbeing Services County of Vantaa and Kerava’s pupil and student welfare work. Also, the pre-primary education provider is legally obligated to provide certain basic information about the pupil to the national centralised integration service for study rights and records (“KOSKI”).

In order to ensure your family’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. A private service provider must also comply with the statutory provisions on confidentiality in its operations. After the end of the client relationship or operations, the private service provider sends the necessary documents to the City of Vantaa for archiving. The service provider provides other original documents to your family after the end of pre-primary education. The service provider is responsible for destroying its files and any copies it has received.

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.

In the case of Microsoft O365 and Google Workspace for Education services/systems, personal data can be transferred to the United States based on the 10 July 2023 decision of the European Commission on the adequacy of data protection level in the United States. The US companies to which data is transferred are certified companies committed to the safeguards agreed between the EU and the US.

Google transfers data applying standard clauses adopted by the European Commission where necessary and where transfers are not subject to an adequacy decision. In addition, Google has an addendum.

Microsoft also complies with the UK extension to the 10 July 2023 decision of the European Commission on the adequacy of data protection level in the United States and the Swiss-US Data Privacy Framework (Swiss-U.S. DPF). In addition, the transfer of personal data outside the EU or EEA is based on Microsoft’s terms.

In the case of the iOS app, the transfer of personal data outside the EU or EEA is based on the terms of Apple services and standard clauses adopted by the European Commission.

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. After the storage period, the data is destroyed. Pre-primary education’s data storage periods vary. For example, the data storage period of the application and decision documents is 10 years.

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 what data is being processed
• request the rectification of erroneous or inaccurate information
• request the erasure of personal data
• request the restriction of the data processing
• 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 make a personal data review request via the e-service, in person at Vantaa Info or by posting the review request form to the City of Vantaa Registry Office. More detailed instructions can be found on the City’s Data Protection page.

If you wish to enforce other rights to which you are entitled as a data subject or request additional information on the processing of personal data, please contact the person specified under section 14 below. The legal basis for the enforcement of your rights is verified on a case-by-case basis. In order to enforce your rights, you may have to prove your identity.

We will fulfil the requests without undue delay, but 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 data. If the deadline is postponed, you will be notified.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 on submitting an appeal are available 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: Lintulahdenkuja 4, FI-00530 Helsinki Postal address: PO Box 800, FI-00531 Helsinki

Email: tietosuoja(at)om.fi

Telephone (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.

Contact person

Jaana Laitio, Planner, early childhood education

firstname.lastname(at)vantaa.fi

tel. +358 40 513 8604

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

Asematie 7, FI-01300 Vantaa

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

Telephone (exchange): +358 9 839 11

Fax +358 9 8392 4163, email: kirjaamo(at)vantaa.fi