Privacy notice: Processing of personnel data
Privacy notice: Processing of personnel data: joint informative document for data subjects (Articles 13 and 14 of the General Data Protection Regulation [2016/679]).
Purposes of processing personal data
Personal data and pay information are processed for employment contract and salary payment purposes.
Data is transmitted to stakeholders (Keva, tax authorities, trade unions) according to regulations.
Legal basis for processing
The basis for processing personal data is our legitimate interest (employment relationship). Main legal instruments include the Finnish Employment Contracts Act, Accounting Act, Working Hours Act and Annual Holidays Act.
In some cases also consent or explicit consent can be basis for processing personal data.
Personal data content and retention periods of the register
Data category name | Retention period |
Name | 75 years from the person’s date of birth |
Personal identity code | 75 years from the person’s date of birth |
E-mail address | 10 years from the end of the last service period |
Address | 10 years from the end of the last service period |
Person’s basic information | 75 years from the person’s date of birth |
Person’s service period data | 75 years from the person’s date of birth |
Employee pay data | 75 years from the person’s date of birth |
Person’s absence information | 10 years from the end of the last service period |
Employee sickness absence information | 10 years from the end of the last service period |
Person’s annual leave information | 10 years from the end of the last service period |
Person’s office location information | 10 years from the end of the last service period |
Person’s working time information | 10 years from the end of the payment year |
Person’s working time information (Repo) | 10 years from the end of the payment year |
Presents, rewards etc. given to the persons | 10 years from the end of the last service period |
Person’s work history information | 10 years from the end of the last service period |
Person’s degree information | 10 years from the end of the last service period |
Person’s personal objectives | 10 years from the end of the last service period |
Person’s job description | 10 years from the end of the last service period |
Person’s development discussion information | 10 years from the end of the last service period |
Person’s competence information | 10 years from the end of the last service period |
Person’s working plans | 10 years from the end of the payment year |
Person’s roles | 10 years from the end of the last service period |
Person’s international mobility information | Retained permanently |
Person’s distraint | Until the end of the year the distraint takes place |
Person’s tax information | Until the entry into force of the following tax card |
Person’s parking space information | 3 years from the end of the employment relationship |
Space reservations made by the person | 10 years from the reservations |
Service requests made by the person | 5 years from the service request |
Sanctions | 1 year from the end of the employment relationship |
Working tools used by the person | Retained as long as the person holds these working tools |
Person’s trade union details | 10 years from the end of the last payment year |
Publication Information | Retained permanently |
Personal files: Microsoft 365 (e-mails and OneDrive), P-drive and Google services | 6 months from the end of the employment relationship |
Personal data received through the Whistleblower channel | 5 years, unless the law requires a longer storage period |
Data subjects
Personnel of Häme University of Applied Sciences, Häme Vocational Institute and HAMK Academy
Regular sources of data
From data subjects themselves.
Data is also obtained from the tax authorities and the enforcement authorities.
Regular disclosures of data
Data is disclosed to banks (salary payment and account balance), tax authorities, Kela, Keva, occupational health care services, trade unions, enforcement authorities. Data may be disclosed from the register for research purposes through research permit procedure.
Statistical data is disclosed to Sivistystyönantajat ry, the Finnish Ministry of Education and Culture and Statistics Finland.
Principles of data protection of the register
A Manual material
Data is archived in paper form in accordance with the archiving plan of the HR services for the period required by law after the employment relationship has ended.
B Data processed through automated data processing
Data is stored in an information system. Users have personal user IDs. Access is granted only to those persons who are entitled to access and use the data in the system in order to perform their duties.
The lawful processing of personal data is ensured by categorisation of data and with operating methods that are in compliance with the data handling rules concerning data set.
Automated decision-making
No automated decision-making is performed on the recorded data.
Transfer of data outside the EU or EEA
If it is necessary to transfer personal data outside EU or ETA area to the countries EU does not have determined adequate level of data protection, the transfer is done by using EU Standard Contractual Clauses. These contractual clauses are available from the data protection officer.
Rights of the data subject
The EU General Data Protection Regulation (2016/679) provides the data subject with the following rights:
The data subject shall have the right to withdraw his or her consent at any time. (Article 7)
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. The data subject shall have the right to access to the personal data concerning him or her. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, the data controller may charge a fee or refuse to act on the request. (Article 12 and Article 15)
The data subject shall have the right to obtain from the data controller the rectification of inaccurate personal data concerning him or her contained in the register (Article 16). A request for rectification shall be submitted in writing. Persons in an employment relationship (with HAMK or HAMI) are able to do rectification suggestions concerning their recorded working hours, which are then approved by their supervisor or salary administration personnel.
The data subject shall have the right to request the erasure of personal data concerning him or her where one of the following grounds applies (Article 17):
- the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- the data subject withdraws consent on which the processing is based and there is no other legal ground for the processing;
- the data subject objects to the processing, and there are no overriding legitimate grounds for the processing (Article 21);
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The data subject shall have the right to obtain restriction of processing where one of the following applies (Article 18):
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where the processing is based on consent and carried out by automated means, the data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a data controller, in a machine-readable format. (Article 20)
Requests to exercise these rights are to be submitted:
Häme University of Applied Sciences Ltd
Data protection officer
P.O. Box 230 (Visamäentie 35A)
FI-13101 Hämeenlinna, Finland
email: [email protected]. You can also send the message via secured e-mail https://www.securedmail.eu/ .
The data subject shall have the right to lodge a complaint with the Office of the Data Protection Ombudsman.
Data controller
Häme University of Applied Sciences Ltd, Häme Vocational Institute Ltd and HAMK Academy Ltd
P.O. Box 230 (Visamäentie 35A), FI-13101 Hämeenlinna
13101 Hämeenlinna
Telephone: +358 3 6461, e-mail address: [email protected]
Contact person of the register
Data protection officer
Häme University of Applied Sciences Ltd
data protection officer
P.O. Box 230
FI-13101 Hämeenlinna