The Digital Wellbeing service

Some of the services are available to residents of Espoo, Karkkila, Vihti and Lohja. The system will be developed in the autumn to provide some of the services to everyone who is living in the Uusimaa area, regardless of their place of residence. We will be updating information concerning the expansion of the services on this page as soon as possible.

The Digital Wellbeing application verifies your municipality of residence with the Digital and Population Data Services Agency’s suomi.fi identification service. This will automatically put you in a service queue in your respective municipality.

• if you have prohibited the disclosure of your personal information, in which case the application cannot obtain the required identification information from the suomi.fi identification service.

The Chat Appointment services and opening hours are initially municipality-specific.

You can contact the chat appointment service at any time, but health care professionals will be available to assist you at the following times:

• Coronavirus helpline Mon-Fri at 7–16.
• Maternity and child health clinic Mon-Fri at 8:30–13:30.
• Student health services Mon-Fri at 9–13.

• Nestori - Guidance and Service Counselling for Senior Citizens Mon-Fri at 9–15.

• Mon–Thu at 8–15, Fri at 8–13
• Respiratory symptoms
• Other symptoms and medical care
• Prescription renewal
• Cancelling an appointment

• Thu at 8:30–15, Wed and Fri at 8:30–13
• Respiratory symptoms
• Other symptoms and medical care
• Prescription renewal
• Examination results
• Changing or cancelling an appointment

You can use

1. the web application at digihyvinvointi.lu-palvelut.fi or
2. the Digital Wellbeing mobile app that can be downloaded for free from App Store (IOS) or Google Play (Android).

1. Open the Digital Wellbeing application.
2. Verify your identity with the service.
3. Select whether you are acting on your own behalf or on behalf of another person. 
4. Answer the questions for preliminary information.
5. A professional will then start the chat with you. If the service is busy, you may have to wait a while for the chat to begin.
6. You will get care instructions, prescriptions and other necessary instructions. If your matter cannot be completed by Chat Appointment, you will be directed to an appropriate service.

You can contact the Chat Appointment service on behalf of someone else. The application verifies the custody information from the suomi.fi e-Authorizations service.

Please note the following:

• Any shared custody agreement may prevent you from acting on behalf of a child.
• You cannot use Chat Appointment if you or the person on behalf of whom you are acting has prohibited the disclosure of personal information because the application cannot, then, obtain the required identification information from the suomi.fi identification service.

These terms of use and the separate privacy statement describe the terms and conditions related to the use of the Chat Appointment service. Before using the service, you must agree to the terms of use of the service and the description of the processing of personal data in the privacy policy. Please read the terms of use and privacy statement carefully before using the service. The terms of use are valid until further notice. Any changes to the terms of use will be notified to the users of the service. If you continue to use the service after the changes, we will consider that you have accepted the changed terms.

The Chat Appointment service allows you to use the instant messaging functionality to chat with social and health care professionals. You can act on behalf of yourself or someone else’s behalf.

To begin with, we may ask you to complete a questionnaire to describe your symptoms. A healthcare professional will receive a summary of your responses, after which they will join the chat. At the end of the chat, you will get an assessment of the need for treatment and, if necessary, you will be directed to the appropriate service.

We may not be able to respond to your messages immediately. Therefore, please note that the Chat Appointment is not for urgent matters. If you feel very unwell or suspect that you have a serious illness, immediately contact your municipality’s health centre or call 112. 

The Digital Wellbeing application is part of the Western Uusimaa social and health services programme. Some of the services are available to residents of Espoo, Karkkila, Vihti and Lohja. Some of the services will be available to everyone who is living in the Uusimaa area, regardless of your place of residence. The service is part of the social and health care services provided by the municipalities, and the municipalities are responsible for the content of the service.

You must register as a user when accessing the application for the first time. You can access the service using the web application at digihyvinvointi.lu-palvelut.fi(extrernal link) or by downloading the mobile application to your IOS or Android smartphone from the respective application store. You must verify your identity with the suomi.fi identification service maintained by the Digital and Population Data Services Agency, for which you will need online banking credentials, a mobile ID or a certificate card. The service cannot be used anonymously. If you have prohibited the disclosure of your personal information, you cannot use the service.

You can use Chat Appointment to act on behalf of someone else. Any shared custody agreement may prevent you from acting on behalf of a child.

As a user, you are responsible for ensuring that the information you provide in the service is correct. You are also responsible for not sending inappropriate, disruptive or illegal content to the service. A summary of your responses to the symptom questionnaire and your chat with the professional will be recorded in the municipal patient information system.

The fees charged for the service are municipality-specific. The service may be subject to a maximum fee according to the municipality’s price list for health centre fees. The fee will be notified to you in the application.

The range of services offered in the Digital Wellbeing application is developed continuously, which is why the content of the services may change. The service provider has the right to change the terms of use of the service, the range of services, charges arising from the use of the service, service times, the appearance of the service or any other feature of the service without prior notice. The service provider has the right to close the service during peak hours to manage the queue, to suspend the service for the duration of maintenance and upgrading operations or to stop offering the service altogether for any other reason.

Date of publication of the privacy statement: 22.11.2021

1. Controller

Espoo Health Services

Address: P.O. Box 202 (Tekniikantie 15), 02070 City of Espoo

2. Person responsible for the register

Director of Health Care Services

Address: City of Espoo Social and Health Services, P.O. Box 202, 02070 City of Espoo

tel. 09 816 21 (exchange)

3. Contact person of the register

Secretary to the Director of Health Care Services

Address: City of Espoo Social and Health Services, P.O. Box 202, 02070 City of Espoo Telephone: 09 816 21 exchange

4. Data protection officer

City of Espoo Data Protection Officer

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

Tel. 09 816 21 (exchange)

E-mail: tietosuoja@espoo.fi

5. For what purpose will personal data be processed?

This privacy statement pertains to the Chat Appointment service of the Digital Wellbeing application. With the Chat Appointment service, a person can use the instant messaging functionality to communicate with social and health care professionals about topics or symptoms related to them or a person on behalf of whom they act.  The service can be accessed using the web application or mobile application downloaded from the appropriate application store. To access the service, the person in question is required to register as a user. Personal data processed in the service is used to organise and provide social and health care services. A social welfare and health care professional records a summary of the discussion in the Chat Appointment service into the municipal client or patient information system. The system supplier and the supplier’s subcontractors process the personal data of the data subjects in service-related support tasks or technical maintenance tasks.

Espoo shall process the personal data for the following purposes:

• organisation, planning, provision, follow-up and counselling related to the examination and treatment of the patient

• provision of health care support services (e.g. application support)

• planning, statistics, follow-up and assessment of social and health care activities pursuant to the Act on the Secondary Use of Health and Social Data or other legislation

• social and health care knowledge management pursuant to the Act on the Secondary Use of Health and Social Data

• scientific research pursuant to the Act on the Secondary Use of Health and Social Data based on separate decisions by Espoo or Findata.

6. On what grounds will personal data be processed?

 Espoo has an obligation to provide health care services to local residents, for example. The organisation of health care services requires the processing of the patients’ personal data. Processing is necessary for compliance with a legal obligation to which Espoo is subject.

Essential legislation

• Data Protection Act (1050/2018)
• Act on the Secondary Use of Health and Social Data (552/2019)
• Act on the Openness of Government Activities (621/1999)
• Act on the Electronic Processing of Client Data in Social and Health Care (159/2007)
• Health Care Act (1326/2010)
• National Health Act (66/1972), Chapter 3
• Government Decree on Maternity and Child Health Clinic Services, School and Student Health Services and Preventive Oral Health Services for Children and Youth (338/2011)
• Act on the Status and Rights of Patients (785/1992)
• Act on Electronic Prescriptions (61/2007)
• Decree on the Openness of Government Activities and on Good Practice in Information Management (1030/1999), Chapter 2
• Administrative Procedure Act (434/2003)
• EU General Data Protection Regulation (in particular Article 6(1)(c) and Article 9(2)(h)).

7. What data will be processed?

Espoo stores the following data based on the use:

• Identification information, such as
  • full name (first names and last name)
  • personal identity code (to identify the data subject)
  • full name of the person being acted on behalf of (first name and last name)
  • personal identity code of the person being acted on behalf of (to identify said person)
  • municipality of residence (to verify the right to act on behalf of someone).
• Contact information, such as
  • telephone number
  • message options (to send notifications)
  • notification ID (the device the notifications are sent).
• Consent information, such as
  • consents (processing of personal data and terms of use).
• Other information provided by the person through the application, such as
  • chat conversation details entered by the person in the application
  • symptom questionnaire responses entered by the person in the application
  • any photographs or attachments uploaded by the person in the application
  • timestamps for tasks completed by the person in the application
  • other information voluntarily provided by the person through the application.
• Booking and appointment information

PUBLIC ACCESS TO INFORMATION AND CONFIDENTIALITY:

The information is confidential.

GROUNDS FOR CONFIDENTIALITY:

Information pertaining to patient relationship is confidential pursuant to Section 24 of the Act on the Openness of Government Activities (621/1999), Section 13 of the Act on the Status and Rights of Patients (785/1992) and Section 17 of the Act on Health Care Professionals (559/1994).

8. What are the sources of data?

Personal data is obtained directly from the person themselves or the person acting on behalf of someone else. The suomi.fi service provides the identification data necessary to ensure the identity and authorisation to act on behalf of someone else.

The following information, for example, can be obtained from the person themselves; telephone number, service language, message options, consents and other health and well-being information provided by the person through the application in relation to the service, e.g. responses to the symptom questionnaire and information and attachments provided in the chat conversation.

Information provided by the suomi.fi includes, for example, the following: full name, personal identity code, municipality of residence, ID for electronic services and the full name and personal identity code of the individual of whom the person is acting on behalf of.

Other regular sources of data include

• the necessary health data provided by the patient, guardian, trustee or relative
• patient care data based on employee observations and examinations
• data from social welfare, health and school services office units or employees, including social work, child welfare, early childhood education, child health clinic, school health care, school teachers and special teachers, school psychologists and school social workers that is obtained with the consent of the patient or their legal representative or on the basis of law.

In relation to health care services, the patient has the right to prohibit the disclosure of information of municipal primary health care and specialised health care in the hospital district (HUS) area within the hospital district. The disclosure of data through the national Patient Data Repository to other healthcare actors is based on the consent of the patient or their legal representative.

Espoo’s right to obtain data on the patient may also be based on other legislation.

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

The data is available to the system suppliers and their subcontractors producing the Digital Wellbeing system insofar as it is necessary for the support tasks or technical maintenance tasks related to the system. Espoo may disclose data about a patient with the explicit consent of the patient or their legal representative. Espoo is obliged on the basis of legislation to disclose data about the patient to other authorities, for example. Before disclosing the data, Espoo shall ensure that the submitter of the request has the right to obtain the data requested on the basis of legislation. Patient data is disclosed to Findata on the basis of the Act on the Secondary Use of Health and Social Data for the purpose of scientific research, statistics, development and innovation activities, teaching, steering and supervision conducted by social welfare and health care authorities and planning and investigation tasks of the authorities. Furthermore, Espoo shall disclose to the submitter of the request on the basis of the Act on the Secondary Use of Health and Social Data data about the patient for the purpose scientific research, statistics, teaching, steering and supervision conducted by social welfare and health care authorities and planning and investigation tasks of the authorities when the request applies to Espoo material only. Espoo may disclose data about a patient on the basis of the Act on the Secondary Use of Health and Social Data for the purposes of knowledge management.

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

As a rule, Espoo shall not transfer data in the register outside the EU or EEA. For example, the data centres for the customer and patient data systems used by Espoo are located in EU or EEA countries. Espoo transfers patient data outside the EU or EEA countries, for example, in case of data exchange between authorities based on law. Espoo transfers patient data outside the EU and EEA countries only if the receiving country has been determined by a decision of the Commission to ensure an adequate level of data protection or the transfer is executed using other appropriate safeguards specified in the EU General Data Protection Regulation (2016/679).

11. How long will data be stored?

The activity history of the Chat Appointment service is stored in the Digital Wellbeing application for five years following its creation, after which the data is deleted by the system supplier. Activity history consists of data related to the service activity in question, including, for example, personal data, symptom questionnaire and the associated responses, chat conversation history, any attachments and service timestamps.

The user account created in connection with the user registration in the Digital Wellbeing application will be deleted five years after the user’s last activity in the application. User account information consists of, for example, the following: name, personal identity code, municipality of residence, ID for electronic services, service language, message options and consents.

The summary recorded by a social and health care professional of the Chat Appointment conversation is stored in Espoo’s patient information system as patient data. With regard to patient data, the patient data retention periods and grounds mentioned below shall be followed.

Processor and user logs are maintained in accordance with the rules and regulations related to the use of patient data. Log data shall be kept for at least the period prescribed by law.

Patient data retention periods are as follows:

• patient documents: as a rule, 120 years after the patient’s birth or 12 years after the patient’s death (patient documents accumulated before 1 May 1999 or relating to patients who died before 1 May 1999: as a rule, 100 years after birth or 20 years after death)
• patient documents of those born on 18th or 28th day: unlimited
• datasets transferred and stored in the National Patient Data Repository: unlimited, except for supporting documentation
• material related to client fees: 10 years.

The retention periods are based on the following grounds:

• Decree of the Ministry of Social Affairs and Health on Patient Documents (298/2009)
• Decision by the National Archives Service on 16 February 2009 (AL/14372/07.01.01.03.01/2008): Permanent storage of patient documents, 2009
• Decision by the National Archives of Finland on the disposal of municipal documents, Part 2. Health care documents. 14 April 1989 ISBN 951-861-419-9.
• Decision by the National Archives Service on 3 September 2001 KA 158/43/01: Permanently stored documents of municipal support and maintenance tasks
• The Association of Finnish Local and Regional Authorities: Retention periods for municipal documents. Provisions and recommendations. Financial administration 2

12. How will data be protected?

IT equipment is located in protected and supervised premises. The equipment and programmes used by Espoo Social and Health Services are protected and secured in accordance with the City’s data security principles. Espoo’s systems require a change of password at regular intervals.

Data is processed by professionals based on client relationship or other appropriate connection. Access rights to the system are granted only to professionals for whom it is necessary for the purpose of providing care or, as the case may be, for the performance of supporting or technical maintenance tasks in relation thereto. Supervisors make decisions regarding granting and removing access rights. Espoo shall cancel the access rights at the end of the employee’s employment relationship. Employees’ access rights are based on personal access rights, and the use of the access rights is controlled by Espoo through log data including a log entry of each time personal data is processed and the processor. Each employee must accept a data and data system user agreement and non-disclosure agreement. Employees who process patient data are legally bound to secrecy. The obligations of confidentiality and secrecy continue also after the end of employment. The processing follows the protocols and procedures for the processing of sensitive health data. Persons who process the data are trained and instructed to process personal data with special care and as securely as possible.

The services, servers and software used to maintain the system are regularly updated, and vulnerabilities and security incidents in the equipment and software covered by the scope of the service are actively monitored.

13. The data subject’s rights

Further instructions on submitting information requests referred to in the General Data Protection Regulation can be found here. 

A data subject, i.e. the patient, or their legal representative has the right to be informed of whether Espoo processes personal data concerning the patient. If Espoo processes personal data concerning the patient, the patient or their legal representative has the right to obtain a copy of the personal data undergoing processing. As a rule, the patient can retrieve their patient data concerning health care services from OmaKanta. At an appointment, an employee can only print the records for that visit upon request by the patient. The right of access to data in accordance with the EU General Data Protection Regulation and the disclosure of records of a visit are different matters. The guardian of an incompetent person has access to the person’s information if the exercise of the right of access is included in the guardianship decision. When submitting a request for access to personal data, the guardian must also provide a copy of the guardianship decision.

A donee of a continuing power of attorney also has the right to access the information of the person in question if the exercise of the right of access is included in the continuing power of attorney. The continuing power of attorney needs to be confirmed by the Digital and Population Data Services Agency or a local register office. When submitting a request for access to personal data, the donee of a continuing power of attorney must also provide a copy of the continuing power of attorney and a copy of the decision of the Digital and Population Data Services Agency or a local register office to confirm the continuing power of attorney.

A third party (i.e., other than the patient or their legal representative) does not have the right of access to data even if personal data concerning them may be stored in the patient’s personal data. A patient or their legal representative may submit a request for access in person at the time of a visit or by means of a document sent by post or by visiting the Registry Office or a service point. Espoo has prepared a request form that the patient or their legal representative can use when requesting access to data. The form is available at the Social and Health Care operational unit and the City of Espoo website. If a patient or their legal representative wishes to submit a request for access to personal data in registers with a free-form document, the patient or their legal representative must indicate in the request what personal data they wish to access, do they wish to access all personal data or data for a specific period of time, and their name, personal identity code and contact details. If the request of access concerns personal data of people other than the submitter, the request must include the name and personal identity code of the person whose data are requested. If the patient or their legal representative submits the request by mail, the request shall be as follows: City of Espoo Social and Health Services, Data requests, P.O. Box 2550, 02070 City of Espoo. If the patient or their legal representative submits a request of access to personal data stored in registers to a unit, Registry Office or service point in person, Espoo shall verify the identity of the submitter from a photo ID.

Espoo shall provide the data without undue delay and in any event within one month of receipt of the request. Where necessary, Espoo may extend that period by a maximum of two months. Espoo shall take into account the complexity and number of requests when extending the period. Espoo shall inform the submitter of the extension to the period and the reasons for it within one month of receipt of the request. Espoo shall inform of refusal to act on the request no later than within one month of receipt of the request. As a rule, Espoo shall provide the requested data to the address of the patient or their legal representative in accordance with the Population Information System.

The General Data Protection Regulation, the Data Protection Act and specific national legislation provide for situations where the controller may refrain from providing the data requested by the patient or their legal representative. If Espoo does not provide the requested data to the patient or their legal representative, Espoo shall promptly and no later than within one month of receipt of the request inform the submitter of the request the reasons for not providing the information, and inform the patient or their legal representative of the possibility of lodging a complaint with the Data Protection Ombudsman and seeking a judicial remedy.

In principle, a request of access to personal data is free of charge. Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, Espoo 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 provide the data requested.

The data subject, i.e. a patient or their legal representative, shall have the right to obtain from Espoo without undue delay the rectification of inaccurate personal data concerning the patient. The patient or their legal representative shall have the right to have incomplete information completed. Espoo shall make the changes so that the register shows information regarding the rectification, the person who made it, the date of the rectification and also the original entry. Espoo is obliged to inform each recipient to whom Espoo has disclosed data concerning the patient of the rectification of the data. Espoo has no obligation to inform if it proves impossible or requires unreasonable effort.

Espoo shall fulfil the request without undue delay and in any event within one month of receipt of the request. Where necessary, Espoo may extend that period by a maximum of two months. Espoo shall take into account the complexity and number of requests when extending the period. Espoo shall inform the submitter of the extension to the period and the reasons for it within one month of receipt of the request. Espoo shall inform of refusal to act on the request no later than within one month of receipt of the request.

If Espoo refuses the request of the patient or their legal representative for the rectification of data, Espoo shall inform the patient or their legal representative of this in writing. Espoo shall also mention the reasons for the refusal and inform the patient or their legal representative of the possibility of lodging a complaint with the Data Protection Ombudsman and seeking a judicial remedy. Espoo may also rectify patient data by supplementing it according to the view of the patient or their legal representative.

The patient or their legal representative have the right to have personal data concerning the patient erased without undue delay subject to compliance with the conditions laid down in Article 17 of the EU General Data Protection Regulation. As a rule, a patient or their legal representative do not have the right to have personal data concerning the patient erased in health care because Espoo is legally obliged to process data (e.g. registration and filing obligation). The right of a patient or their legal representative to have personal data concerning the patient erased mainly applies to data originally unnecessary to its intended purpose. Espoo is obliged to inform each recipient to whom Espoo has disclosed data concerning the patient of the erasure of the data. Espoo has no obligation to inform if it proves impossible or requires unreasonable effort. A patient or their legal representative may submit requests to erase data to the following address: City of Espoo Social and Health Services, Data requests, P.O. Box 2550, 02070 City of Espoo.

A patient or their legal representative have the right to request Espoo to restrict the processing of personal data concerning the patient if the patient or their legal representative challenges the accuracy of the personal data concerning the patient. In this case, Espoo shall normally restrict the processing of personal data concerning the patient until Espoo has verified the accuracy of the personal data. The data protection regulation provides for certain exceptions to the obligation to restrict, which allow Espoo to process personal data subject to restriction under certain circumstances. Espoo must inform the patient or their legal representative of the removal of the restriction before removing it. A patient or their legal representative may submit requests to restrict the processing of data to the following address: City of Espoo Social and Health Services, Data requests, P.O. Box 2550, 02070 City of Espoo.

A patient or their legal representative has the right to lodge a complaint with the Data Protection Ombudsman in Finland if the patient or their legal representative considers that Espoo does not process personal data concerning the patient in compliance with data protection legislation. More detailed instructions on how to lodge a complaint can be found on the website of the Data Protection Ombudsman’s Office https://tietosuoja.fi/en/home(extrernal link). The right of lodge a complaint with the Data Protection Ombudsman shall be without prejudice to any other administrative or judicial remedy available to the patient or their legal representative.

Date of release: 3 November 2021

Karviainen, federation of municipalities for healthcare and social services  Address: P.O. Box 114, 03100 Nummela  

Address: Nummenselkä 2, 03100 Nummela 
Phone: 09 4258 2000 (switchboard) 

Service manager in charge of healthcare   

Address: Nummenselkä 2, 03100 Nummela 

Phone: 09 4258 2000 (switchboard) 

Karviainen's data protection officer 

Address: P.O. Box 114, 03100 Nummela   Phone: 09 816 21 (switchboard) 

e-mail: tietosuojavastaava@karviainen.fi 

This privacy statement is for the Chat Appointment service of the Digital Wellbeing application.   Users can rely on an instant-messaging feature, the chat, to communicate with social and healthcare  professionals about topics or symptoms related to them or related to someone they represent.  Chat  Appointment can be accessed using the web app or mobile app downloaded from the appropriate  app store. To access Digital Wellbeing, users must first submit an application for registration as a  user. Personal data processed in Digital Wellbeing is used to organise and provide social and  healthcare services. A social welfare and health care professional records a summary of the  discussion in the chat, saving it in the municipal client or patient information system. The system  supplier and the supplier’s subcontractors process the personal data of the data subjects when  performing tasks that are service-related support tasks, or technical tasks related to system  maintenance. 

The Karviainen federation of municipalities processes the personal data and patients' information  for the following purposes: 

• Organisation, planning, provision, follow-up, rehabilitation, control of quality, and counselling,  relating to the examination and treatment of the patients; 
• Provision of healthcare support services (e.g. application support and billing accounts); 
• Planning, statistics, follow-up and assessment of social and healthcare activities, pursuant to the  Act on the Secondary Use of Health and Social Data or other legislation;
• Knowledge management in the sectors of social and healthcare, pursuant to the Act on the  Secondary Use of Health and Social Data, and 
• Scientific research, pursuant to the Act on the Secondary Use of Health and Social Data, based on  separate decisions that the Karviainen federation or Findata may make on the subject of research. 

Karviainen, the federation of municipalities for healthcare and social services, is under obligation  to provide healthcare services to municipal residents and to others.  The organisation of healthcare services requires the processing of the patients’ personal data.  Processing is necessary for compliance with the legal obligation to provide healthcare. 

List of relevant legal statutes: 

• EU General Data Protection Regulation, GDPR (in particular Article 6(1)(c) and Article 9(2)(h))  Data Protection Act (1050/2018) 
• Act on the Secondary Use of Health and Social Data (552/2019) 
• Act on the Openness of Government Activities (621/1999) 
• Act on the Electronic Processing of Client Data in Social and Health Care (159/2007) 
• Health Care Act (1326/2010) 
• National Health Act (66/1972), Chapter 3 
• Government Decree on Maternity and Child Health Clinic Services, School and Student Health  Services and Preventive Oral Health Services for Children and Youth (338/2011) 
• Act on the Status and Rights of Patients (785/1992) 
• Act on Electronic Prescriptions (61/2007) 
• Decree on the Openness of Government Activities and on Good Practice in Information 
  Management (1030/1999), Chapter 2 
• Administrative Procedure Act (434/2003) 
• EU General Data Protection Regulation (in particular Article 6(1)(c) and Article 9(2)(h)) 

Karviainen stores the following data based on system use: 

• Identification information, such as 
  • full name (first names and last name) 
  • personal identity code (to identify the data subject) 
  • full name of the person being acted on behalf of (first name and last name)
  • personal identity code of the person being acted on behalf of (to identify said person)
  • municipality of residence (to verify the right to act on behalf of someone) 
• Contact information, such as 
  • telephone number 
  • message options (to send notifications) 
  • notification ID (the device the notifications are sent) 
• Information about giving consent, such as 
  • consents (processing of personal data and terms of use) 
• Other information provided by the person through the application, such as 
  • information entered or recorded by the person chatting and using the app 
  • symptom questionnaire responses entered by the person in the app 
  • any photographs or attachments uploaded by the person in the app 
  • timestamps for tasks completed by the person in the app 
  • other information voluntarily provided by the person through the app 
• Information relating to bookings and appointments 

PUBLIC ACCESS TO INFORMATION;  STATEMENT OF CONFIDENTIALITY:  The information is confidential. 

GROUNDS FOR CONFIDENTIALITY: 

Information having to do with the healthcare relationship between medical staff and the patient is  confidential pursuant to Section 24 of the Act on the Openness of Government Activities  (621/1999), Section 13 of the Act on the Status and Rights of Patients (785/1992) and Section 17 of  the Act on Health Care Professionals (559/1994). 

Personal data is obtained directly from the data subject himself/herself or from the person  authorised to represent the data subject. The suomi.fi service provides the identification data  necessary to ensure the identity and authorisation to act on behalf of someone else. 

The following information, for example, can be obtained from the person themselves; telephone  number, service language, message options, consents and other health and well-being information  provided by the person through the application in relation to the service, e.g. responses to the 
symptom questionnaire and information and attachments provided in the chat conversation. 

Information provided by Suomi.fi covers the following: full name, personal identity code,  municipality of residence, ID for electronic services and the full name and personal identity code of  the patient or other individual being represented. 

Other regular sources of data include: 

• The necessary health data provided by the patient, guardian, trustee or relative 
• Patient care data based on the observations and examinations by healthcare employees 
• Data from social welfare, health and school services office units or employees, including 

social work, child welfare, early childhood education, child health clinic, school health care,  school teachers and special teachers, school psychologists and school social workers that is  obtained with the consent of the patient or their legal representative or on the basis of law. 

In relation to health care services, the patient has the right to prohibit the disclosure of information  of municipal primary health care and specialised health care in the hospital district (HUS) area  within the hospital district. The disclosure of data through the national Patient Data Repository to  other healthcare actors is based on the consent of the patient or their legal representative. 

Karviainen’s right to obtain data on the patient may also be based on other legislation. 

The data is available to the system suppliers and their subcontractors producing the Digital  Wellbeing system insofar as it is necessary for the support tasks or technical maintenance tasks  related to the system.  

Karviainen may disclose data about a patient with the explicit consent of the patient or their legal  representative. Karviainen is under a legal obligation to disclose data about the patient to other  authorities and to certain other recipients. No such disclosure is carried out by the Karviainen  federation until a check has been made to ascertain that the data is requested by a party that has  a legal right to receive the data.  

In addition, Karviainen may disclose data to service providers (in case of outsourced services, etc.)  if disclosure of patient information is essential for the production of the healthcare service being  provided. Under provisions of relevant law, Karviainen also discloses data about patients to the  authorities in charge of control and supervision (including the Regional administrative authority,  and the Finnish parliament’s ombudsman). 

Patient data is disclosed to Findata on the basis of the Act on the Secondary Use of Health and  Social Data for the purpose of scientific research, statistics, development and innovation activities, teaching, steering and supervision conducted by social welfare and health care authorities and  planning and investigation tasks of the authorities. Furthermore, Karviainen will disclose to the  requesting party, as provided in the Act on the Secondary Use of Health and Social Data,  information about the patient for the purpose scientific research, statistics, teaching, steering and  supervision conducted by social welfare and health care authorities and planning and investigation  tasks of the authorities when the request applies to Karviainen material only. Karviainen can  additionally disclose data about a patient on the basis of the Act on the Secondary Use of Health  and Social Data for purposes of knowledge management. 

As a rule, Karviainen will not transfer data in the register outside the EU or EEA. For example, the  data centres for the customer and patient data systems used by Karviainen are located in EU or EEA  countries. Karviainen transfers patient data outside the EU or EEA countries, for example, in case  of data exchange between authorities based on law. Karviainen transfers patient data outside the EU  and EEA countries only if the receiving country has been determined by a decision of the  Commission to ensure an adequate level of data protection or the transfer is executed using other  appropriate safeguards specified in the EU General Data Protection Regulation (2016/679). 

The activity history of the Chat Appointment service is stored in the Digital Wellbeing application  for five years following its creation, after which the data is deleted by the system supplier. Activity  history consists of data related to the service activity in question, including, for example, personal  data, symptom questionnaire and the associated responses, chat conversation history, any  attachments and service timestamps. 

The user account created in connection with the user registration in the Digital Wellbeing  application will be deleted five years after the user’s last activity in the application. User account  information consists of, for example, the following: name, personal identity code, municipality of  residence, ID for electronic services, service language, message options and consents. 

The summary recorded by a social and health care professional of the Chat Appointment  conversation is stored in Karviainen’s patient information system as patient data. With regard to  patient data, the patient data retention periods and grounds mentioned below will be followed. 

Processor and user logs are maintained in accordance with the rules and regulations related to the  use of patient data. Log data will be kept for at least the period prescribed by law. 

Patient data retention periods are as follows:

• patient documents: as a rule, 120 years after the patient’s birth or 12 years after the patient’s 

death (patient documents accumulated before 1 May 1999 or relating to patients who died  before 1 May 1999: as a rule, 100 years after birth or 20 years after death)

• patient documents of those born on 18th or 28th day: unlimited
• datasets transferred and stored in the National Patient Data Repository: unlimited, except for 

supporting documentation

• material related to client fees: 10 years. 

The retention periods are based on the following grounds:

• Decree of the Ministry of Social Affairs and Health on Patient Documents (298/2009)
• Decision by the National Archives Service on 16 February 2009 (AL/14372/07.01.01.03.01/2008): Permanent storage of patient documents, 2009
• Decision by the National Archives of Finland on the disposal of municipal documents, Part 2. Health care documents. 14 April 1989 ISBN 951-861-419-9. 
• Decision by the National Archives Service on 3 September 2001 KA 158/43/01: Permanently stored documents of municipal support and maintenance tasks 
• The Association of Finnish Local and Regional Authorities: Retention periods for municipal 

documents. Provisions and recommendations. Financial administration 2 

IT equipment is located in protected and supervised premises. The equipment and programmes used  by Karviainen are protected and secured in accordance with the Karviainen’s data security  principles. Karviainen’s systems require a change of password at regular intervals. 

Data is processed by professionals based on client relationship or other appropriate connection.  Access rights to the system are granted only to professionals for whom it is necessary for the 
purpose of providing care or, as the case may be, for the performance of supporting or technical  maintenance tasks in relation thereto. Supervisors make decisions regarding granting and removing  access rights. Karviainen will cancel the access rights at the end of the employee’s employment  relationship. Employees’ access rights are based on personal access rights, and the use of the access  rights is controlled by Karviainen through log data including a log entry of each time personal data 
is processed and the processor. Each employee must accept a data and data system user agreement  and non-disclosure agreement. Employees who process patient data are legally bound to secrecy.  The obligations of confidentiality and secrecy continue also after the end of employment. The  processing follows the protocols and procedures for the processing of sensitive health data. Persons  who process the data are trained and instructed to process personal data with special care and as  securely as possible. 

The services, servers and software used to maintain the system are regularly updated, and  vulnerabilities and security incidents in the equipment and software covered by the scope of the  service are actively monitored. 

The data subject’s rights 

Further instructions on submitting information requests referred to in the General Data Protection 
Regulation can be found here: https://karviainen.fi/asiointi/tietosuoja/(extrernal link).  

The data subject, i.e. the patient, and his or her legal representative, has the right to be informed of  whether Karviainen processes personal data concerning the patient. If Karviainen processes 

personal data concerning the patient, the patient or their legal representative has the right to obtain a copy of the personal data undergoing processing. As a rule, the patient can retrieve their patient data concerning health care services from OmaKanta. At an appointment, an employee can only print the records for that visit upon request by the patient. The right of access to data in accordance with the EU General Data Protection Regulation and the disclosure of records of a visit are different matters.  The guardian of an incompetent person has access to the person’s information if the exercise of the right of access is included in the guardianship decision. When submitting a request for access to  personal data, the guardian must also provide a copy of the guardianship decision. 

A donee of a continuing power of attorney also has the right to access the information of the person  in question if the exercise of the right of access is included in the continuing power of attorney. The  continuing power of attorney needs to be confirmed by the Digital and Population Data Services Agency or a local register office. When submitting a request for access to personal data, the donee of a continuing power of attorney must also provide a copy of the continuing power of attorney and  a copy of the decision of the Digital and Population Data Services Agency or a local register office  to confirm the continuing power of attorney. 

A third party (i.e., other than the patient or his/her representative) does not have the right of access to data even if personal data concerning them may be stored in the patient’s personal data. A patient  or their legal representative may submit a request for access in person, at the time of a visit, or by  means of a document, sent by post or hand-delivered to the Registrar’s Office or a service point.  Karviainen has prepared a request form that the patient or their legal representative can use when  requesting access to data. The form is available on the Karviainen federation's website,  https://karviainen.fi/asiointi/tietosuoja/(extrernal link).  

If a patient or their legal representative wishes to submit a request for access to personal data in 
registers with a free-form document, the patient or their legal representative must indicate in the  request what personal data they wish to access, do they wish to access all personal data or data for a  specific period of time, and their name, personal identity code and contact details. If the request of  access concerns personal data of people other than the submitter, the request must include the name  and personal identity code of the person whose data are requested. If the patient or their legal  representative submits the request by mail, the request will be as follows send the request letter to:  Karviainen, the Registrar's Office, P.O. Box 114, 03100 Nummela.   If the patient or the patient’s  legal  representative submits a request for access to personal data stored in registers to a unit, to the Registrar's Office or to a service point in person, Karviainen will verify the identity of the  submitter by demanding a photo ID card to be presented. 

Karviainen will provide the data without undue delay and in any event within one month of receipt  of the request. Where necessary, Karviainen may extend that period by a maximum of two months.  Karviainen will take into account the complexity and number of requests when extending the period. Karviainen will inform the submitter of the extension to the period and the reasons for it  within one month of receipt of the request. Karviainen will inform of refusal to act on the request no  later than within one month of receipt of the request. As a rule, Karviainen will provide the requested data to the address of the patient or their legal representative in accordance with the  Population Information System. 

The General Data Protection Regulation, the Data Protection Act and specific national legislation  provide for situations where the controller may refrain from providing the data requested by the  patient or their legal representative. If Karviainen does not provide the requested data to the patient  or their legal representative, Karviainen will promptly and no later than within one month of receipt  of the request inform the submitter of the request the reasons for not providing the information, and  inform the patient or their legal representative of the possibility of lodging a complaint with the 

Data Protection Ombudsman and seeking a judicial remedy. 

In principle, a request of access to personal data is free of charge. Where requests from a data  subject are manifestly unfounded or excessive, in particular because of their repetitive character,  Karviainen 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 provide the  data requested.

The data subject, i.e. a patient or their legal representative, will have the right to obtain from  Karviainen without undue delay the rectification of inaccurate personal data concerning the patient.  The patient or their legal representative will have the right to have incomplete information  completed. Karviainen will make the changes so that the register shows information regarding the  rectification, the person who made it, the date of the rectification and also the original entry.  Karviainen is obliged to inform each recipient to whom Karviainen has disclosed data concerning  the patient of the rectification of the data. Karviainen has no obligation to inform if it proves  impossible or requires unreasonable effort. 

Karviainen will fulfil the request without undue delay and in any event within one month of receipt  of the request. Where necessary, Karviainen may extend that period by a maximum of two months.  Karviainen will take into account the complexity and number of requests when extending the period. Karviainen will inform the submitter of the extension to the period and the reasons for it  within one month of receipt of the request. Karviainen will inform of refusal to act on the request no  later than within one month of receipt of the request.

If Karviainen refuses the request of the patient or their legal representative for the rectification of  data, Karviainen will inform the patient or their legal representative of this in writing. Karviainen  will also mention the reasons for the refusal and inform the patient or their legal representative of  the possibility of lodging a complaint with the Data Protection Ombudsman and seeking a judicial  remedy. Karviainen may also rectify patient data by supplementing it according to the view of the patient or their legal representative. 

The patient or their legal representative have the right to have personal data concerning the patient  erased without undue delay subject to compliance with the conditions laid down in Article 17 of the  EU General Data Protection Regulation. As a rule, a patient or their legal representative do not have  the right to have personal data concerning the patient erased in health care because Karviainen is  legally obliged to process data (e.g. registration and filing obligation). The right of a patient or their  legal representative to have personal data concerning the patient erased mainly applies to data 
originally unnecessary to its intended purpose. Karviainen is obliged to inform each recipient to  whom Karviainen has disclosed data concerning the patient of the erasure of the data. Karviainen 

has no obligation to inform if it proves impossible or requires unreasonable effort. A patient or their  legal representative may submit requests to erase data to the following address: Karviainen, the 
Registrar's Office, P.O. Box 114, 03100 Nummela. 

A patient or their legal representative have the right to request Karviainen to restrict the processing  of personal data concerning the patient if the patient or their legal representative challenges the  accuracy of the personal data concerning the patient. In this case, Karviainen will normally restrict  the processing of personal data concerning the patient until Karviainen has verified the accuracy of  the personal data. The data protection regulation provides for certain exceptions to the obligation to  restrict, which allow Karviainen to process personal data subject to restriction under certain  circumstances. Karviainen must inform the patient or their legal representative of the removal of the  restriction before removing it. A patient or their legal representative may submit requests to restrict  the processing of data to the following address: Karviainen, the Registrar's Office, P.O. Box 114,  03100 Nummela. 

A patient or their legal representative has the right to lodge a complaint with the Data Protection  Ombudsman in Finland if the patient or their legal representative considers that Karviainen does not  process personal data concerning the patient in compliance with data protection legislation. More  detailed instructions on how to lodge a complaint can be found on the website of the Data 

Protection Ombudsman’s Office https://tietosuoja.fi/en/home(extrernal link). The right of lodge a complaint with  the Data Protection Ombudsman will be without prejudice to any other administrative or judicial  remedy available to the patient or their legal representative. 

1. Controller

Lohja Social and Health Services

P.O. BOX 71 (Karstuntie 4), 08100 Lohja

2. Person responsible for the register

Director of Social and Health Services

Tuula Suominen

Address: City of Lohja, P.O. BOX 71, 08100 Lohja

Tel 019 3690 (exchange)

3. Contact person of the register

Sanna Lundström

Address: City of Lohja, P.O. BOX 71, 08100 Lohja

Tel 019 3690 (exchange)

4. Data protection officer

City of Lohja Data Protection Officer

Address: Karstuntie 4, P.O. BOX 71, 08100 Lohja

Tel 019 3690 (exchange)

E-mail: kirjaamo@lohja.fi

5. For what purpose will personal data be processed?

This privacy statement pertains to the Chat Appointment service of the Digital Wellbeing application. With the Chat Appointment service, a person can use the instant messaging functionality to communicate with social and health care professionals about topics or symptoms related to them or a person on behalf of whom they act.  The service can be accessed using the web application or mobile application downloaded from the appropriate application store. To access the service, the person in question is required to register as a user. Personal data processed in the service is used to organise and provide social and health care services. A social welfare and health care professional records a summary of the discussion in the Chat Appointment service into the municipal client or patient information system. The system supplier and the supplier’s subcontractors process the personal data of the data subjects in service-related support tasks or technical maintenance tasks.

Lohja shall process the personal data for the following purposes:

• organisation, planning, provision, follow-up and counselling related to the examination and treatment of the patient

• provision of health care support services (e.g. application support)

• planning, statistics, follow-up and assessment of social and health care activities pursuant to the Act on the Secondary Use of Health and Social Data or other legislation

• social and health care knowledge management pursuant to the Act on the Secondary Use of Health and Social Data

• scientific research pursuant to the Act on the Secondary Use of Health and Social Data based on separate decisions by Lohja or Findata.

6. On what grounds will personal data be processed?

Lohja has an obligation to provide health care services to local residents, for example. The organisation of health care services requires the processing of the patients’ personal data. Processing is necessary for compliance with a legal obligation to which Lohja is subject.

Essential legislation

• Data Protection Act (1050/2018)
• Act on the Secondary Use of Health and Social Data (552/2019)
• Act on the Openness of Government Activities (621/1999)
• Act on the Electronic Processing of Client Data in Social and Health Care (159/2007)
• Health Care Act (1326/2010)
• National Health Act (66/1972), Chapter 3
• Government Decree on Maternity and Child Health Clinic Services, School and Student Health Services and Preventive Oral Health Services for Children and Youth (338/2011)
• Act on the Status and Rights of Patients (785/1992)
• Act on Electronic Prescriptions (61/2007)
• Decree on the Openness of Government Activities and on Good Practice in Information Management (1030/1999), Chapter 2
• Administrative Procedure Act (434/2003)
• EU General Data Protection Regulation (in particular Article 6(1)(c) and Article 9(2)(h)).

7. What data will be processed?

Lohja stores the following data based on the use:

• Identification information, such as
  • full name (first names and last name)
  • personal identity code (to identify the data subject)
  • full name of the person being acted on behalf of (first name and last name)
  • personal identity code of the person being acted on behalf of (to identify said person)
  • municipality of residence (to verify the right to act on behalf of someone).
• Contact information, such as
  • telephone number
  • message options (to send notifications)
  • notification ID (the device the notifications are sent).
• Consent information, such as
  • consents (processing of personal data and terms of use).
• Other information provided by the person through the application, such as
  • chat conversation details entered by the person in the application
  • symptom questionnaire responses entered by the person in the application
  • any photographs or attachments uploaded by the person in the application
  • timestamps for tasks completed by the person in the application
  • other information voluntarily provided by the person through the application.
• Booking and appointment information

PUBLIC ACCESS TO INFORMATION AND CONFIDENTIALITY:

The information is confidential.

GROUNDS FOR CONFIDENTIALITY:

Information pertaining to patient relationship is confidential pursuant to Section 24 of the Act on the Openness of Government Activities (621/1999), Section 13 of the Act on the Status and Rights of Patients (785/1992) and Section 17 of the Act on Health Care Professionals (559/1994).

8. What are the sources of data?

Personal data is obtained directly from the person themselves or the person acting on behalf of someone else. The suomi.fi service provides the identification data necessary to ensure the identity and authorisation to act on behalf of someone else.

The following information, for example, can be obtained from the person themselves; telephone number, service language, message options, consents and other health and well-being information provided by the person through the application in relation to the service, e.g. responses to the symptom questionnaire and information and attachments provided in the chat conversation.

Information provided by the suomi.fi includes, for example, the following: full name, personal identity code, municipality of residence, ID for electronic services and the full name and personal identity code of the individual of whom the person is acting on behalf of.

Other regular sources of data include

• the necessary health data provided by the patient, guardian, trustee or relative
• patient care data based on employee observations and examinations
• data from social welfare, health and school services office units or employees, including social work, child welfare, early childhood education, child health clinic, school health care, school teachers and special teachers, school psychologists and school social workers that is obtained with the consent of the patient or their legal representative or on the basis of law.

In relation to health care services, the patient has the right to prohibit the disclosure of information of municipal primary health care and specialised health care in the hospital district (HUS) area within the hospital district. The disclosure of data through the national Patient Data Repository to other healthcare actors is based on the consent of the patient or their legal representative.

Lohja’s right to obtain data on the patient may also be based on other legislation.

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

The data is available to the system suppliers and their subcontractors producing the Digital Wellbeing system insofar as it is necessary for the support tasks or technical maintenance tasks related to the system.

Lohja may disclose data about a patient with the explicit consent of the patient or their legal representative.

 Lohja is obliged on the basis of legislation to disclose data about the patient to other authorities, for example.

 Before disclosing the data, Lohja shall ensure that the submitter of the request has the right to obtain the data requested on the basis of legislation.

Patient data is disclosed to Findata on the basis of the Act on the Secondary Use of Health and Social Data for the purpose of scientific research, statistics, development and innovation activities, teaching, steering and supervision conducted by social welfare and health care authorities and planning and investigation tasks of the authorities.

Furthermore, Lohja shall disclose to the submitter of the request on the basis of the Act on the Secondary Use of Health and Social Data data about the patient for the purpose scientific research, statistics, teaching, steering and supervision conducted by social welfare and health care authorities and planning and investigation tasks of the authorities when the request applies to Lohja material only.

Lohja may disclose data about a patient on the basis of the Act on the Secondary Use of Health and Social Data for the purposes of knowledge management.

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

As a rule, Lohja shall not transfer data in the register outside the EU or EEA.

For example, the data centres for the customer and patient data systems used by Lohja are located in EU or EEA countries.

Lohja transfers patient data outside the EU or EEA countries, for example, in case of data exchange between authorities based on law.

Lohja transfers patient data outside the EU and EEA countries only if the receiving country has been determined by a decision of the Commission to ensure an adequate level of data protection or the transfer is executed using other appropriate safeguards specified in the EU General Data Protection Regulation (2016/679).

11. How long will data be stored?

The activity history of the Chat Appointment service is stored in the Digital Wellbeing application for five years following its creation, after which the data is deleted by the system supplier. Activity history consists of data related to the service activity in question, including, for example, personal data, symptom questionnaire and the associated responses, chat conversation history, any attachments and service timestamps.

The user account created in connection with the user registration in the Digital Wellbeing application will be deleted five years after the user’s last activity in the application. User account information consists of, for example, the following: name, personal identity code, municipality of residence, ID for electronic services, service language, message options and consents.

The summary recorded by a social and health care professional of the Chat Appointment conversation is stored in Lohja’s patient information system as patient data. With regard to patient data, the patient data retention periods and grounds mentioned below shall be followed.

Processor and user logs are maintained in accordance with the rules and regulations related to the use of patient data. Log data shall be kept for at least the period prescribed by law.

Patient data retention periods are as follows:

• patient documents: as a rule, 120 years after the patient’s birth or 12 years after the patient’s death (patient documents accumulated before 1 May 1999 or relating to patients who died before 1 May 1999: as a rule, 100 years after birth or 20 years after death)
• patient documents of those born on 18th or 28th day: unlimited
• datasets transferred and stored in the National Patient Data Repository: unlimited, except for supporting documentation
• material related to client fees: 10 years.

The retention periods are based on the following grounds:

• Decree of the Ministry of Social Affairs and Health on Patient Documents (298/2009)
• Decision by the National Archives Service on 16 February 2009 (AL/14372/07.01.01.03.01/2008): Permanent storage of patient documents, 2009
• Decision by the National Archives of Finland on the disposal of municipal documents, Part 2. Health care documents. 14 April 1989 ISBN 951-861-419-9.
• Decision by the National Archives Service on 3 September 2001 KA 158/43/01: Permanently stored documents of municipal support and maintenance tasks
• The Association of Finnish Local and Regional Authorities: Retention periods for municipal documents. Provisions and recommendations. Financial administration 2

12. How will data be protected?

IT equipment is located in protected and supervised premises. The equipment and programmes used by Lohja Social and Health Services are protected and secured in accordance with the City’s data security principles. Lohja’s systems require a change of password at regular intervals.

Data is processed by professionals based on client relationship or other appropriate connection. Access rights to the system are granted only to professionals for whom it is necessary for the purpose of providing care or, as the case may be, for the performance of supporting or technical maintenance tasks in relation thereto. Supervisors make decisions regarding granting and removing access rights. Lohja shall cancel the access rights at the end of the employee’s employment relationship. Employees’ access rights are based on personal access rights, and the use of the access rights is controlled by Lohja through log data including a log entry of each time personal data is processed and the processor. Each employee must accept a data and data system user agreement and non-disclosure agreement. Employees who process patient data are legally bound to secrecy. The obligations of confidentiality and secrecy continue also after the end of employment. The processing follows the protocols and procedures for the processing of sensitive health data. Persons who process the data are trained and instructed to process personal data with special care and as securely as possible.

The services, servers and software used to maintain the system are regularly updated, and vulnerabilities and security incidents in the equipment and software covered by the scope of the service are actively monitored.

13. The data subject’s rights

A data subject, i.e. the patient, or their legal representative has the right to be informed of whether Lohja processes personal data concerning the patient. If Lohja processes personal data concerning the patient, the patient or their legal representative has the right to obtain a copy of the personal data undergoing processing. As a rule, the patient can retrieve their patient data concerning health care services from OmaKanta. At an appointment, an employee can only print the records for that visit upon request by the patient. The right of access to data in accordance with the EU General Data Protection Regulation and the disclosure of records of a visit are different matters. The guardian of an incompetent person has access to the person’s information if the exercise of the right of access is included in the guardianship decision. When submitting a request for access to personal data, the guardian must also provide a copy of the guardianship decision.

A donee of a continuing power of attorney also has the right to access the information of the person in question if the exercise of the right of access is included in the continuing power of attorney. The continuing power of attorney needs to be confirmed by the Digital and Population Data Services Agency or a local register office. When submitting a request for access to personal data, the donee of a continuing power of attorney must also provide a copy of the continuing power of attorney and a copy of the decision of the Digital and Population Data Services Agency or a local register office to confirm the continuing power of attorney.

A third party (i.e., other than the patient or their legal representative) does not have the right of access to data even if personal data concerning them may be stored in the patient’s personal data. A patient or their legal representative may submit a request for access in person at the time of a visit or by means of a document sent by post or by visiting the Registry Office or a service point. Lohja has prepared a request form that the patient or their legal representative can use when requesting access to data. The form is available at the Social and Health Care operational unit and the City of Lohja website https://www.lohja.fi/sosiaali-ja-terveyspalvelut/terveyspalvelut-2/hallinto-ja-palaute/(extrernal link). If a patient or their legal representative wishes to submit a request for access to personal data in registers with a free-form document, the patient or their legal representative must indicate in the request what personal data they wish to access, do they wish to access all personal data or data for a specific period of time, and their name, personal identity code and contact details. If the request of access concerns personal data of people other than the submitter, the request must include the name and personal identity code of the person whose data are requested. If the patient or their legal representative submits the request by mail, the request shall be as follows: City of Lohja/Kirjaamo, Karstuntie 4 P.O. BOX 71, 08100 Lohja.. If the patient or their legal representative submits a request of access to personal data stored in registers to a unit, Registry Office or service point in person, Lohja shall verify the identity of the submitter from a photo ID.

Lohja shall provide the data without undue delay and in any event within one month of receipt of the request. Where necessary, Lohja may extend that period by a maximum of two months. Lohja shall take into account the complexity and number of requests when extending the period. Lohja shall inform the submitter of the extension to the period and the reasons for it within one month of receipt of the request. Lohja shall inform of refusal to act on the request no later than within one month of receipt of the request. As a rule, Lohja shall provide the requested data to the address of the patient or their legal representative in accordance with the Population Information System.

The General Data Protection Regulation, the Data Protection Act and specific national legislation provide for situations where the controller may refrain from providing the data requested by the patient or their legal representative. If Lohja does not provide the requested data to the patient or their legal representative, Lohja shall promptly and no later than within one month of receipt of the request inform the submitter of the request the reasons for not providing the information, and inform the patient or their legal representative of the possibility of lodging a complaint with the Data Protection Ombudsman and seeking a judicial remedy.

In principle, a request of access to personal data is free of charge. Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, Lohja 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 provide the data requested.

The data subject, i.e. a patient or their legal representative, shall have the right to obtain from Lohja without undue delay the rectification of inaccurate personal data concerning the patient. The patient or their legal representative shall have the right to have incomplete information completed. Lohja shall make the changes so that the register shows information regarding the rectification, the person who made it, the date of the rectification and also the original entry. Lohja is obliged to inform each recipient to whom Lohja has disclosed data concerning the patient of the rectification of the data. Lohja has no obligation to inform if it proves impossible or requires unreasonable effort.

Lohja shall fulfil the request without undue delay and in any event within one month of receipt of the request. Where necessary, Lohja may extend that period by a maximum of two months. Lohja shall take into account the complexity and number of requests when extending the period. Lohja shall inform the submitter of the extension to the period and the reasons for it within one month of receipt of the request. Lohja shall inform of refusal to act on the request no later than within one month of receipt of the request.

If Lohja refuses the request of the patient or their legal representative for the rectification of data, Lohja shall inform the patient or their legal representative of this in writing. Lohja shall also mention the reasons for the refusal and inform the patient or their legal representative of the possibility of lodging a complaint with the Data Protection Ombudsman and seeking a judicial remedy. Lohja may also rectify patient data by supplementing it according to the view of the patient or their legal representative.

The patient or their legal representative have the right to have personal data concerning the patient erased without undue delay subject to compliance with the conditions laid down in Article 17 of the EU General Data Protection Regulation. As a rule, a patient or their legal representative do not have the right to have personal data concerning the patient erased in health care because Lohja is legally obliged to process data (e.g. registration and filing obligation). The right of a patient or their legal representative to have personal data concerning the patient erased mainly applies to data originally unnecessary to its intended purpose. Lohja is obliged to inform each recipient to whom Lohja has disclosed data concerning the patient of the erasure of the data. Lohja has no obligation to inform if it proves impossible or requires unreasonable effort. A patient or their legal representative may submit requests to erase data to the following address: City of Lohja/Kirjaamo, Karstuntie 4 P.O. BOX 71, 08100 Lohja.

A patient or their legal representative have the right to request Lohja to restrict the processing of personal data concerning the patient if the patient or their legal representative challenges the accuracy of the personal data concerning the patient. In this case, Lohja shall normally restrict the processing of personal data concerning the patient until Lohja has verified the accuracy of the personal data. The data protection regulation provides for certain exceptions to the obligation to restrict, which allow Lohja to process personal data subject to restriction under certain circumstances. Lohja must inform the patient or their legal representative of the removal of the restriction before removing it. A patient or their legal representative may submit requests to restrict the processing of data to the following address: City of Lohja/Kirjaamo, Karstuntie 4 P.O. BOX 71, 08100 Lohja.

A patient or their legal representative has the right to lodge a complaint with the Data Protection Ombudsman in Finland if the patient or their legal representative considers that Lohja does not process personal data concerning the patient in compliance with data protection legislation. More detailed instructions on how to lodge a complaint can be found on the website of the Data Protection Ombudsman’s Office https://tietosuoja.fi/en/home(extrernal link). The right of lodge a complaint with the Data Protection Ombudsman shall be without prejudice to any other administrative or judicial remedy available to the patient or their legal representative.