Processing of personal data: Client register of right-of-occupancy numbers and dwellings

Processing of personal data

Client register of right-of-occupancy numbers and dwellings

Date of publication: 27 May 2024

1. Data controller

Cities of Helsinki and Espoo

The register is shared by the cities of Helsinki and Espoo. The queue numbers are applied for from the same place, but Espoo makes the decisions on right-of-occupancy dwellings located in Espoo, and Helsinki makes the decisions on right-of-occupancy dwellings located in the other cities included in the application area.

The use and maintenance of the register ended on 31 December 2023, but its data will be stored in the CGI database until the end of 2025. The data can be requested from the database through a separate information request. Only a contact person named in the agreement may submit an information request to CGI. After 2025, the data will be completely erased.

2. Person responsible for the register

Housing Manager, Urban Environment Sector

Address: P.O. Box 49, 02070 City of Espoo

Tel. +358 40 353 3582

Email address: asumisoikeus@espoo.fi

3. Contact person of the register

Planning Officer, Urban Environment Sector

Address: P.O. Box 49, 02070 City of Espoo

Tel. +358 43 824 5773

Email address: asumisoikeus@espoo.fi

4. Data Protection Officer

Data Protection Officer of the City of Espoo

Address: P.O. Box 12, 02070 City of Espoo

Tel. 09 816 21 (switchboard)

Email address: tietosuoja@espoo.fi

5. For what purpose is personal data processed?

Personal data is processed for the purpose of allocating right-of-occupancy queue numbers and processing applications for approval as a right-of-occupancy recipient and applications for giving up the right of occupancy. The right-of-occupancy application area includes the cities of Helsinki, Espoo, Vantaa, Hyvinkää, Järvenpää, Kerava, Kirkkonummi, Mäntsälä, Nurmijärvi, Pornainen, Sipoo, Tuusula, Vihti and Porvoo.

Under the Right-of-Occupancy Housing Act, a municipality issues the queue numbers (section 4c), approves the recipients of right of occupancy (section 4a) and confirms the maximum price of the dwelling when someone gives up their right of occupancy (section 24).

The municipality will not approve the recipients of right of occupancy or confirm the maximum prices after 31 August 2023. The queue numbers previously issued by the municipality cannot be used after 31 December 2023.

6. On what grounds is personal data processed?

  • Article 6(1)(a) of the General Data Protection Regulation of the European Union: the data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Article 6(1)(b) of the General Data Protection Regulation of the European Union: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • 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.

Key legislation:

  • Data Protection Act (1050/2018)
  • Right-of-occupancy Housing Act (651/1990)
  • Administrative Procedure Act (434/2003)
  • Act on the Openness of Government Activities (621/1999)

7. What data is processed?

The register contains the names, personal identity codes, addresses and possible contact details of the holders of right of occupancy in the application area. In addition, the register contains the details on right-of-occupancy dwellings located in the area, including the owner, property name, address, dwelling size, dwelling type, property completion or acquisition date, and the right-of-occupancy fee.

The register does not contain information recorded after 31 December 2023.

PUBLIC ACCESS TO AND CONFIDENTIALITY OF DATA:

The data is confidential.

GROUNDS FOR CONFIDENTIALITY:

Act on the Openness of Government Activities 621/1999, section 24, subsection 1, paragraph 23.

8. What are the sources of data?

The applicant provides their personal data when applying for a queue number.

Personal data is also obtained from right-of-occupancy companies and, if necessary, it is also checked from the population information system.

The queue numbers needed for applying for a right-of-occupancy dwelling are personal, which is why applicants are required to provide their personal data.

Queue numbers have not been available through the system after 31 December 2023.

9. Will data be disclosed or transferred outside the city?

Personal data is disclosed to owners of right-of-occupancy dwellings (those owners who propose applicants as recipients of right of occupancy).

10. Will data be transferred outside the EU/EEA?

Data is not transferred outside the EU.

11. How long will data be stored?

Queue numbers and related personal data are stored permanently.

Decisions and related documents are stored for 10 years.

12. How is data protected?

INFORMATION SYSTEMS

Electronic data is stored in the client system for right-of-occupancy queue numbers and dwellings. The system contains the information on clients and dwellings mentioned in the register. Access rights to the system are granted on a task-specific basis, and each user must log in using their personal user ID. Each user must accept the user agreement and non-disclosure agreement concerning the data and the information systems.

MANUAL MATERIALS

Applications for approval as a right-of-occupancy recipient and applications to give up the right of occupancy as well as related decisions are stored in paper form in a locked archive space.

13. Rights of the data subject

Further instructions on submitting information requests referred to in the General Data Protection Regulation: Data protection / Clients’ right of access to personal data

13.1. How can I access my data?

You have the right to obtain from the data controller a copy of the personal data that is subject to processing. The data controller must provide the data without undue delay and in any event within one month of receipt of 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 controller does not take action on the request of the data subject, the 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 free of charge. However, where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, the data 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.

13.2 When can I request rectification of my data?

You have the right to have inaccurate, incomplete, outdated or unnecessary personal data that we store either rectified or completed by us.

13.3. When can I request erasure of my data?

You have the right to have the data controller erase your personal data without undue delay under certain conditions. The data subject does 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 data controller. In these cases, the data will only be erased after the statutory time limit.

13.4. When can I request restriction of processing of my data?

If the data concerning you is inaccurate, you have the right to request that its processing be restricted until its accuracy has been verified.

13.5. 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: www.tietosuoja.fi(external link, opens in a new window)