Privacy notice: Processing of personal data on the City of Espoo’s social media accounts

Date of publication: 21 November 2024

This privacy notice describes how the City of Espoo processes personal data on social media.  

The City of Espoo creates content for social media platforms. The city has social media accounts on Facebook, Instagram, Threads, X, LinkedIn, YouTube, TikTok and Snapchat. These accounts are public, meaning that users can view the posts without following the accounts, provided that this is enabled by the platform.

The processing of personal data is also affected by each platform’s own privacy policies, which are available on the respective platforms: 

•    Facebook (external link, opens in a new window)
•    Instagram (external link, opens in a new window)
•    Threads (external link, opens in a new window)
•    LinkedIn (external link, opens in a new window)
•    X(external link, opens in a new window)  
•    YouTube(external link, opens in a new window) 
•    TikTok (external link, opens in a new window)
•    Snapchat (external link, opens in a new window) 

Johanna Pajakoski, Director of Communications, City of Espoo
Address: P.O. Box 12, 02070 City of Espoo
Tel. +358 9 81621 (switchboard)
Email: firstname.lastname@espoo.fi 

Paula Häkämies, Senior Specialist
Address: P.O. Box 12, 02070 City of Espoo
Tel. +358 9 81621 (switchboard)
Email: firstname.lastname@espoo.fi 

Data Protection Officer of the City of Espoo
Address: P.O. Box 12, 02070 City of Espoo
Tel. +358 9 81621 (switchboard) 
Email: tietosuoja@espoo.fi

Personal data is processed for the purpose of providing residents and other stakeholders with information about the city’s activities and to enable discussion on current topics. 

The processing of personal data is based on the municipality’s obligation to provide information. According to section 29 of the Local Government Act, residents, service users, organisations and other corporate entities must be informed about the municipality’s activities. The municipality must provide sufficient information about the services it organises, its finances, matters under preparation in the municipality, related plans, the processing of these matters, decisions made and their impacts. The municipality must provide information on how people can participate in and influence the preparation of decisions. Provisions on the obligation of public authorities to produce and share information are also laid down in section 20 of the Act on the Openness of Government Activities. 

In addition, data is processed to manage social media accounts and ensure that discussions are appropriate.

Data is also processed to evaluate and develop social media communication.  

Article 6(1)(e) of the General Data Protection Regulation of the European Union: 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. 

The grounds for processing personal data in connection with social media giveaways and competitions is the participant’s consent in accordance with Article 6(1)(a) of the General Data Protection Regulation.

The city’s social media accounts are public, meaning that users can view the posts without following the accounts, provided that this is enabled by the platform.

On social media platforms, data that users have made public on the platform is processed.

The following personal data is processed: 

• user’s name
• user’s contact information
• user’s username
• posts made by the user. 

Users can send private messages to the City of Espoo on social media platforms. Users can also write public comments on the city’s social media accounts and react publicly to our posts. The City of Espoo can participate in discussions on social media platforms and respond to private messages and comments.

Social media service providers provide the City of Espoo with demographic data on those who follow and visit the city’s social media accounts. This data includes age and gender, general information on professional and educational background, and location data.

Social media service providers provide the City of Espoo with summary reports on how many different users have seen a post, how many times the post has appeared to different users and how users have interacted with the post. 

Individual users cannot be identified from this data.

On social media platforms, data that users have made public on the platform or data processed about them within the social media service is processed. 

The City of Espoo only discloses personal data to other authorities who have a legal right to access the data.  

The City of Espoo does not transfer personal data outside the EU or EEA. Social media platform servers may be located outside the EU/EEA, and in such cases data transfers follow the platforms’ own privacy policies.

The City of Espoo targets its communication on social media to effectively reach residents and other stakeholders for whom the information is relevant. 

Communication is targeted based on demographic data, such as age and gender, general information related to professional and educational background, location data, and interests.  In addition, the City of Espoo targets its communication based on the language users use on social media platforms. 

Social media service providers provide the City of Espoo with information on how many different users have seen a targeted post, how many times the targeted post has been seen, and where the targeted post was displayed. Reports on targeted communication contain general demographic data and information on how users interacted with the posts. Individual users cannot be identified from this data. 

When targeting communication to social media users, the City of Espoo acts as a joint data controller together with the social media service provider. 

When creating targeted posts, the City of Espoo defines the parameters for the target audience, while the social media service provider uses the social media users’ personal data to deliver targeted posts. The City of Espoo does not have access to the personal data of the relevant users.  

Users can check within social media services why they are seeing targeted posts. The user can also choose to disable targeted posts.  

The City of Espoo organises giveaways and competitions on its social media accounts. Social media competitions and giveaways are conducted in accordance with the terms and conditions set by social media service providers. Read more about the rules of the City of Espoo’s Facebook and Instagram competitions.

The City of Espoo obtains personal data collected in connection with a giveaway or competition from the participants. Personal data collected in connection with giveaways and competitions include: first and last name, username in the social media service, email address, and postal address. 

The City of Espoo only processes information provided by the participant.  The purpose of processing personal data is to facilitate participation in the competition and to deliver the prize to the winner.

The City of Espoo does not disclose personal data for marketing purposes. To deliver the prize, the City of Espoo may provide the necessary personal data to an external prize provider, but only with the winner’s consent.

The City of Espoo may announce the winner’s name or social media username on its social media channels after the giveaway or competition ends. However, this will only be done with the winner’s consent.

Social media service providers determine how long personal data is stored on their social media platforms.

For matters related to the exercise of data subject rights, you can contact either the City of Espoo or the social media platform provider. 
Right to lodge a complaint 

You have the right to lodge a complaint with a supervisory authority if you feel that the processing of your personal data is in infringement of data protection legislation. You can lodge a complaint with the Office of the Data Protection Ombudsman(external link, opens in a new window).