Privacy notice: Processing of personal data, client register for early childhood education services

Date of publication: 26 July 2024 (Updated: 4 September 2025)

City of Espoo

Virpi Mattila, Director of Finnish Early Childhood Education

Barbro Högström, Director of Swedish Education and Cultural Services

Email: firstname.lastname@espoo.fi

Tel. +358 9 81621 (switchboard)

System specialists Sari Kuittinen and Sirpa Koljonen

Email: evakatuki@espoo.fi

Tel. +358 9 81621 (switchboard)

Helena Niemi, 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

The personal data stored in this register is processed for the purposes of organising early childhood education and taking care of tasks that arise from the early childhood education provider’s relationship with the child (section 5 of the Act on Early Childhood Education and Care). Espoo offers early childhood education as a municipal service, as an outsourced service, and through service vouchers. Personal data stored in the register may also be processed when it is necessary for the purposes of testing the information systems, for example when a new information system is introduced in early childhood education.

The register is used for compiling statistics for the City of Espoo. When statistics are compiled, the data is processed anonymously.

Article 6(1)(c) of the General Data Protection Regulation of the European Union: processing is necessary for compliance with a legal obligation to which the controller is subject.

Special categories of personal data: According to section 6 of the Data Protection Act, Article 9(1) of the General Data Protection Regulation does not apply to any processing of data that is provided by law or that derives directly from a statutory duty set out for the data controller by law. Processing of special categories of personal data is derived from duties set out for an early childhood education provider by law.

Special categories of personal data to be processed may include health information.

Key legislation:

• General Data Protection Regulation of the European Union (2016/679)
• Data Protection Act (1050/2018)
• Act on Early Childhood Education and Care (540/2018)
• Government Decree on Early Childhood Education and Care (753/2018)
• Act on Client Fees in Early Childhood Education and Care (1503/2016)
• Act on Service Vouchers in Social Welfare and Health Care Services (569/2009).

The processing of personal identity codes is based on section 29, subsections 1 and 2 of the Data Protection Act. The identification of the data subject and their personal data is important for the performance of a statutory duty. Personal identity codes are also processed to enable client invoicing in early childhood education.

Information system and forms related to early childhood education:

The following data to be stored in the information system pertains to municipal, outsourced and service voucher units:

• Child’s name, personal identity code, contact information and mother tongue
• Guardians’ names, personal identity codes, contact information and mother tongue
• Information on the early childhood education unit and the need for services
• Agreement on early childhood education hours
• Information on the child’s day-to-day attendance and absences
• Other information and forms needed for the provision of early childhood education
• Name, personal identity code and contact information of other persons living in a shared household with the child
• Application information
• Decisions related to the client relationship
• Information on acceptance and cancellation of a place in early childhood education
• Early childhood education support measures
• Names and telephone numbers of other persons authorised to pick up the child
• Child’s early childhood education plan
• Pedagogic documentation (e.g. photos and videos of children’s activities)
• Child’s photograph
• Health information needed for the organisation of early childhood education, such as special diet, allergies, medication
• Information on transport decision
• Nationality of the child and the guardian, grounds for and validity period of residence permit for the purpose of applying for reimbursement of special costs related to the early childhood education of a child with refugee status

The following data to be stored in the information system only pertains to municipal units:

Some data that is stored in the early childhood education client information system is transferred to the invoicing system used to invoice early childhood education clients.

Case management system for immigration affairs (UMA)

• Child’s guardians
• Early childhood education employees, service providers, persons responsible for outsourced and service voucher units
• Client information is obtained from the Digital and Population Data Services Agency
• An earlier provider of early childhood education may disclose public information that is needed for the organisation of the child’s early childhood education (section 16, subsection 3 of the Act on the Openness of Government Activities).
• An earlier provider of early childhood education must, without delay and notwithstanding provisions relating to secrecy, disclose the information that is needed for the organisation of the child’s early childhood education (section 41, subsection 3 of the Act on Early Childhood Education and Care)
• Education authorities, health care and social welfare authorities, other early childhood education, health care and social welfare service providers, and health care and social welfare professionals may, notwithstanding provisions relating to secrecy, disclose information that is needed for the organisation of the child’s early childhood education (section 41, subsection 1 of the Act on Early Childhood Education and Care).
• Case management system for immigration affairs (UMA) maintained by the Finnish Immigration Service (Migri)

Data and documents are disclosed to the person requesting them in accordance with the Act on the Openness of Government Activities. Information and documents are public unless specifically defined as confidential under law.

The City of Espoo may use operational or technical service providers to provide the service. The service providers process personal data on behalf of the City of Espoo and according to its instructions, to the extent that is necessary to enable service provision.

Service providers (processors) that process data through eVaka (early childhood education information system) on behalf of the City of Espoo: There is a contractual relationship between the City of Espoo and Digia, and Amazon is Digia’s sub-processor.

Varda

Varda’s purposes: to enable secure and centralised electronic collection, processing and disclosure of early childhood education data to the data subject in question, their legal representative and to authorities and researchers in need of such data; to ensure the consistency and reliability of statutory early childhood education data and enhance administrative operations; to promote early childhood education development and decision-making based on accurate and sufficient information.

Data stored in this register is disclosed to Varda, the national data warehouse for early childhood education and care. Varda is part of the set of registers and data warehouses maintained by the Finnish National Agency for Education. With regard to the processing of personal data in Varda, The Finnish National Agency for Education acts as Varda’s joint controller with the City of Espoo. You can access Varda’s privacy notice through this link: Varda-palvelun tietosuojaseloste - Opintopolku(external link, opens in a new window) (in Finnish)

Case management system for immigration affairs (UMA)

To retrieve the data, the personal identity code or name of the guardian or child is entered into the UMA system.

As the data controller, the city uses personal data processors (service providers). The early childhood education information system uses a cloud service provided by Amazon. Processors may transfer data from the register outside the European Union or the European Economic Area only if the transfer meets the applicable statutory requirements and if the transfer and appropriate protection measures have been agreed upon between the controller and the processor as required by data protection legislation.

The storage location of Amazon’s cloud service is within the EU. If Amazon operates and develops services from outside Europe, data is considered to be transferred outside the EU. For example, if an administrator connects remotely from the United States to a European data centre to resolve an issue. In these situations, safeguards are established to maintain the high level of data protection required by European legislation even after the personal data has been transferred. These safeguards include an adequacy decision by the European Commission and a commitment to the required safeguards, such as the EU-US Data Privacy Framework, by the recipient of personal data. Required safeguards may also include the use of standard contractual clauses adopted by the European Commission as part of agreements concluded with personal data processors, in addition to which the processors are required to observe appropriate technical and administrative safeguards.

Data is stored and destroyed in line with the City of Espoo’s records management plan and the applicable provisions and regulations issued by the National Archives of Finland.

The child’s data is stored in the system until ten (10) years have passed since the end of the calendar year during which the child’s early childhood education ended. After the archiving period, the data is deleted from the electronic system either automatically or by the administrator. Permanently stored digitally produced documents are transferred to the electronic archiving system Särmä.

Permanently stored documents include the child’s early childhood education plan. Administrative decisions on support are stored for 10 years after the end of compulsory education. Other physical materials are destroyed at the end of the storage period.

Data protection legislation guarantees various rights for the data subject in relation to the processing of personal data. Requests concerning the data subject’s rights can be submitted to the city’s Data Protection Officer or the contact person of the register using the above-mentioned contact details.

If necessary, the controller may ask the data subject to provide additional information to fulfil the request.

The controller must respond to a request concerning the data subject’s rights without undue delay and no later than one month after receiving the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

If the data controller does not take action on the request of the data subject, the data controller must inform the data subject without delay, and at the latest within one month of receipt of the request, of the reasons for not taking action and of the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

Requests from the data subject and any resulting actions are, as a rule, free of charge. However, where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the controller may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request.

The data subject shall have the right to obtain from the controller confirmation as to whether personal data concerning him or her is being processed as well as the right to access the data and to obtain a copy of the data. However, the provision of data shall not adversely affect the rights or freedoms of others.

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. In addition, taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed.

Under certain conditions, the data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her. For example, if the processing of personal data is based on consent and the data subject withdraws his or her consent and there is no other legal ground for the processing, the data subject shall have the right to have his or her data erased. However, the data subject shall not have the right to erasure if the processing of data is necessary for compliance with a legal obligation or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The data subject shall have the right to request the restriction of processing in certain situations. For example, if the accuracy of the personal data is contested by the data subject, processing is restricted for a period enabling the controller to verify the accuracy of the personal data. The right also applies if the data subject has objected to processing pending the verification of whether the legitimate grounds of the controller override those of the data subject.

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her, which is processed for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. In such a situation, the controller may only continue processing the personal data if the controller demonstrates compelling legitimate grounds for the processing. Processing may also continue if it is necessary for the establishment, exercise or defence of legal claims.

The data subject shall have the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes data protection legislation. The data subject can lodge a complaint with the Office of the Data Protection Ombudsman: www.tietosuoja.fi(external link, opens in a new window).

Change history:

4 September 2025

Section 7      Content of early childhood education client register specified

Section 11     Data storage periods specified