Privacy Policy for the Register of Elected Officials and the Register of Private Interests

Privacy policy
General Data Protection Regulation of the European Union (2016/679)
Privacy Policy for the Register of Elected Officials and the Register of Private Interests

1. Data controller

The County Board of the Western Uusimaa Wellbeing Services County

2. Person responsible for the register

Director of Administration (for the Register of Elected Officials)

Audit Committee (for the Register of Private Interests)

3. Contact person of the register

Head of Decision-Making Support Services (for the Register of Elected Officials)

Evaluation Manager (for the Register of Private Interests)

Contact details

Western Uusimaa Wellbeing Services County

P.O. Box 33, 02033 Western Uusimaa Wellbeing Services County

Switchboard: 029 151 2000

4. Purposes of processing personal data and the legal grounds for processing

Purposes of processing

Personal data are processed for the purpose of receiving and monitoring declarations of private interests submitted by the wellbeing services county’s key elected officials and senior office-holders. The purpose of declaring private interests is to increase the openness and transparency of decision-making. In addition, the register is used to record positions of trust, maintain contact, and process and pay fees and reimbursements to elected officials. Personal data may also be processed for the purposes of personnel security clearance. The personal data of office-holders involved in the work of decision-making bodies are processed to the extent necessary for the operation of those bodies.

Legal grounds for processing

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.

The processing of information of political positions of elected officials is permissible under Article 9(2)(e) of the EU General Data Protection Regulation, which allows the processing of personal data that the registered individual has made explicitly public.

Key legislation

  • General Data Protection Regulation of the European Union (679/2016)
  • Data Protection Act (1050/2018)
  • Act on the Openness of Government Activities (621/1999)
  • Act on Wellbeing Services Counties (611/2021)
  • Act on Public Officials in Local Government and Wellbeing Services Counties (304/2003)
  • Security Clearance Act 726/2014

5. Data content of the register

The Register of Elected Officials and the Register of Private Interests contain information reported by elected officials and office-holders on their management positions and positions of trust in companies and other entities engaged in business activities, their significant assets, and other private interests that may be relevant to the performance of their duties as elected officials or office-holders.

For the purposes of registration, contact, and the processing and payment of fees and reimbursements, the data subjects entered in the Register of Elected Officials and the Register of Private Interests include all members and deputy members of the County Board. With regard to private interests, the data subjects include the wellbeing services county’s key elected officials (members and deputy members of the County Board, the chairperson and vice-chairpersons of the County Council, and the chairpersons and vice-chairpersons of Committees), as well as senior office-holders (the Wellbeing Services County Director and the presenting officials of the County Board and Committees), who are subject to a statutory obligation to declare private interests that may be relevant to the performance of their duties as elected officials or office-holders.

The Register of Elected Officials and the Register of Private Interests contain:

  • identification details (such as first name, last name, personal identity code and date of birth)
  • contact details (such as address, telephone number and email address)
  • occupation
  • bank account details
  • party affiliation details (such as party membership, tax information and expense reimbursements granted)
  • positions of trust and public offices, management positions and other positions of trust, significant assets (including ownership of land and forest, shareholdings, debt or guarantees), and other private interests declared by the person subject to the reporting obligation, where such information may be relevant to the performance of duties as an elected official or office-holder.

6. Regular disclosure of personal data

Declarations of private interests are submitted to the County Council for information in accordance with section 125(2)(5) of the Act on Wellbeing Services Counties. In addition, the Register of Private Interests is published on the wellbeing services county’s website in the public information network in accordance with section 89(4) of the Act on Wellbeing Services Counties.‌ Accordingly, anyone has the right to access information on declared private interests. The Register of Private Interests may contain confidential information referred to in section 24 of the Act on the Openness of Government Activities. To the extent that such information is confidential, it will not be published online or disclosed without a statutory basis.

Otherwise, data in the register are not regularly disclosed to third parties. Data may primarily be disclosed on the basis of the data subject’s written consent. In addition, data may be disclosed where disclosure is expressly provided for by law.

As described above, certain data are made available in the public information network. Otherwise, data are not disclosed outside the European Union or the European Economic Area.

7. Data retention periods

Data in the Register of Elected Officials and the Register of Private Interests are retained for the duration of the position of trust or the office-holder’s term of office. Declarations of private interests and data in the Register of Private Interests are retained permanently in accordance with a decision of the National Archives (AL/10361/07.01.03.01/2017, 30 June 2017). Information on declared private interests is kept available in the public information network for the duration of the reporting person’s position of trust or term as an office-holder. When the position of trust or term of office ends, the data concerning that person are removed from the public information network.

8. Sources of personal data

As a rule, data in the Register of Elected Officials and the Register of Private Interests are obtained from the persons subject to the reporting obligation themselves.  Information on the email address used in positions of trust is obtained from the user management register.