Privacy policy: Client register of the social services

Privacy policy
General Data Protection Regulation of the European Union (2016/679)

Client register of the social services

1. Data controller

The County Board of the Western Uusimaa Wellbeing Services County

2. Person responsible for the register

For services for the elderly, the service area director 

For services for children, young people and families, the service area director

For joint social services, such as adult social services, the service area director

For disability services, the service area director

3. Contact persons for the register

Administrative Managers for the service areas

Contact information

Western Uusimaa Wellbeing Services County

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

Switchboard’s phone number: 029 151 2000

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

The purposes of processing

The purpose of processing personal data in the register is to assess and determine the need for services for social welfare clients under the Social Welfare Act, as well as the planning, implementation, and monitoring of these services.

In addition, data is processed for the purposes of processing client fees and collecting payment data.

Client documents from social services are also used for planning, statistical analysis, supervision, assessment, self-supervision, knowledge management, and scientific research of the work in social welfare services, as laid down in the Act on the Secondary Use of Health and Social Data or as otherwise provided for by law.

Legal grounds for processing

Article 6(1) point (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.

As a special category of personal data, health information is processed under Article 9 (2)(h), which permits data processing when necessary for the provision of social care.

Key legislation

  • General Data Protection Regulation of the European Union (679/2016)
  • Data Protection Act (1050/2018)
  • Social Welfare Act (1301/2014)
  • Act on the Status and Rights of Social Welfare Clients (812/2000)
  • Act on Client Charges in Healthcare and Social Welfare (734/1992)
  • Decree on Client Charges in Healthcare and Social Welfare (912/1992)
  • Act on the Processing of Client Data in Healthcare and Social Welfare (703/2023)
  • Act on Social Welfare Client Documentation (254/2015)
  • Act on Supporting the Functional Capacity of the Older Population and on Social and Health Services for Older Persons (980/2012)
  • Act on Social Assistance (1412/1997)
  • Act on Support for Informal Care (937/2005)
  • Act on Service Vouchers for Social Welfare and Health Care (569/2009)
  • Act on Welfare for Substance Abusers (41/1986)
  • Administrative Procedure Act (434/2003)
  • Act on the Openness of Government Activities (621/1999)
  • Municipality of Residence Act (201/1994)
  • Child Welfare Act (2007/417)
  • Family Care Act (263/2015)
  • Act on Residential Leases (481/1995)
  • Act on the Reception of Persons Applying for International Protection and on the Identification of and Assistance to Victims of Trafficking in Human Beings (746/2011)
  • Act on the Promotion of Immigrant Integration (1386/2010)
  • Aliens Act (301/2004)
  • Act on Social Lending (1133/2002)
  • Act on Special Care for People with Intellectual Disabilities (519/1977)
  • Act on Disability Services and Assistance (380/1987)
  • Act on Support for Informal Care (937/2005)
  • Act on Service Vouchers for Social Welfare and Health Care (569/2009)
  • Parenthood Act (775/2022)
  • Act on Child Custody and Right of Access (361/1983)
  • Child Custody and Right of Access Decree (556/1994)
  • Child Maintenance Act (704/1975)
  • Act on Child Maintenance Allowance (580/2008)
  • Adoption Act (22/2012)
  • Student Welfare Act (1287/2013)
  • Act on Client Charges in Healthcare and Social Welfare (734/1992)
  • Act on Organising Healthcare and Social Welfare Services (612/2021)
  • Act on Organising Healthcare, Social Welfare and Rescue Services in the Region of Uusimaa (615/2021)

5. Contents of the register

The client's basic information, information related to the provision of social services, and information related to client fees are processed in the register.

In the case of all social services, client identification and contact information (personal identity code, name, preferred first name, gender, address, telephone numbers, municipality of residence, mother tongue, service language, marital status, email address and other necessary contact information) are processed, as well as information necessary for the provision of service (information concerning the need for services, application data and contacts, data on appointments and visits, summaries, statements, notes related to client work and contact with clients, service decisions and decisions on fees and related notifications). In addition, the processed information includes information that the client produces or provides about themselves, as well as information on prohibitions, restrictions, consent, and other preference data.

Additionally, for working-age people (i.e. adults), the following information is necessary for service provision:

- Information required for promoting the integration of clients with a refugee background, and for organising and implementing their social services.

- Information required to organise and implement services for children and young people who arrived in the country as unaccompanied asylum seekers, including their after-care services.

- Information required for the payment and collection of benefits and grants.

- Information necessary for granting, paying out, and collecting social loans.

- Information required for debt relief.

- Information necessary to produce statutory settlements.

In the context of organising child welfare services, the following additional information is required:

- Information recorded in child welfare notifications.

- Information related to the management of clients’ funds.

- Documentation concerning applications and training of family carers, substitute carers, and supporting family carers, as well as decisions and notes made during their work. - Client-specific commission agreements within family care. - The person’s family information (guardian, dependant, number and ages of children under 18, housing information, household size).

- Client information related to the daily operations of the care facilities.

Additional information necessary to process within family law services consists of the following:

- For child welfare officers: information pertaining to the identification and confirmation of parenthood, contracts and decisions, income and wealth information, and notes recorded during client work. For assessment of circumstances: court requests for assessments along with related attachments, assessments prepared for the court along with related attachments, and requests for information and statements. For child contact centre activities: contracts and decisions. For the inter-family adoption register: the current stage of the adoption process and the person’s family information (guardian, dependant, number and ages of children under 18, housing information, household size).

Additional information necessary to process within services for the elderly consists of:

- Information on relatives.

- Information on research and treatment programs.

- The name, position, company or organisation, and contact details (phone number, email address, address) of the person acting as the contact person in the nursing home.

Additional information necessary to process within the Disability Services consists of:

- The person’s family information (guardian, dependant, number and ages of children under 18, housing information, household size).

- Client information related to the daily operations of the care facilities.

- Registered transport services will process the location data of the transports.

6. Disclosure of personal data in accordance with legislation

Personal data is disclosed, based on legislation or a detailed information request, to authorised authorities in accordance with the legislation.

Under the Secondary Use Act, information concerning clients is provided to Findata for the purpose of scientific research, statistics, development and innovation activities, teaching, social and healthcare authority guidance and supervision as well as for planning and reporting duties of authorities. In addition, under the Secondary Use Act, the Wellbeing Services County discloses client information for applicants for the purpose of scientific research, statistics, teaching, social and healthcare authority guidance and supervision as well as for planning and reporting duties of authorities, when the application pertains only to the data maintained by the Wellbeing Services County.

In addition, the Wellbeing Services County discloses client information to service providers (e.g., in the case of outsourced services) if necessary for the provision of the client’s social service. On legislative grounds, the Wellbeing Services County will also disclose client information to supervisory authorities (e.g., AVI, EOA, Valvira).

Each autumn, the child welfare services send the school authorities of the Wellbeing Services County’s municipalities a list of 6–17-year-old children who are subject to compulsory education and have been placed in the area. The list of the children is sent for the purpose of organising their education.

In the context of family law services, as part of the work of child welfare officers, the Wellbeing Services County will disclose information and documents related to the confirmation of paternity to the Digital and Population Data Services Agency for confirmation of paternity in accordance with legislation. Furthermore, as part of the work of child welfare officers, the Wellbeing Services County will electronically disclose the decision to confirm a child custody agreement to the maintainer of the Population Information System in accordance with legislation. On legislative grounds and as part of the work of child welfare officers, the Wellbeing Services County will disclose personal, income and wealth, paternity, and contract information as attachments to requests for executive assistance to various authorities whose tasks include handling similar matters. In accordance with legislation, the Wellbeing Services County will disclose reports on a family’s situation for the court that requested the report.

As a rule, data is not transferred from the register to countries outside the EU or the EEA. However, personal data may be transferred to countries outside the EU/EEA area where the European Commission has determined that the level of data protection is adequate. In addition, personal data may be transferred to countries outside the EU/EEA when the protection measures required by the General Data Protection Regulation have been implemented, for example, by incorporating standard data protection clauses into contracts and by employing additional measures recommended by the European Data Protection Board as necessary.

7. Data storage periods

Storage periods for client documents are defined in the appendix concerning storage times for client documents of the Act on the Processing of Client Data in Healthcare and Social Welfare (703/2023) as well as in decisions on storage times for client documents and decisions by the National Archives of Finland. 

Clientship documents and basic client information: 2 years after the client's death. 

Client documents concerning services for families with children: 30 years after the case closure. 

Client documents concerning services for working-aged people: 10 years after the case closure. 

Client documents concerning services for the elderly: 10 years after the case closure. 

Client documents concerning substance abuse services: 10 years after the case closure. 

Client documents concerning disability services: 10 years after the last matter concludes, when the need for services has ended. 

Client documents concerning child welfare services: 2 years after the client's death. 

Client documents concerning family law services: 120 after the child’s birth for matters involving a child; 10 years after case closure for other matters.  

Vouchers/receipts/certificates: 3 years. 

Income statements and decisions on client charges: 12 years after the decision's validity ends. 

Client-specific communications and correspondence related to services: 3 years from the date of the message (or equivalent). 

For individuals born on the 8th, 18th, or 28th of any month, we permanently retain certain documents. These include social service reports, decision records from office holders (pertaining to substance abuse, child welfare, and special care programs for individuals with intellectual disabilities), paternity determination documents, and decisions related to foster care (including placement, changes, termination or continuation of custody, and contact restrictions.  

Additionally, all electronically stored social welfare client documents and information (excluding receipts) that can be retrospectively transferred and are intended for the national social welfare client data repository, as per The Act on the Electronic Processing of Client Data in Healthcare and Social Welfare (159/2007), are permanently stored in electronic form.

8. Sources of personal data

The Digital and Population Data Services Agency primarily provides clients’ identification and contact information, such as name and address.

Information in the social services client register related to organising services is obtained and maintained based on information received from the client or their representative as well as on information produced within social service units.

In accordance with the conditions set out in section 20 of the Act on the Status and Rights of Social Welfare Clients, the Wellbeing Services County also has the ability to request client information without the client’s consent from state and municipal authorities, other public law entities, Kela, the Finnish Centre for Pensions, the pension foundation and other pension institutions, insurance companies, education providers, social service providers, health and medical care communities and operational units, healthcare professionals, and financial institutions. In such cases, the requested information must be crucial to the social service client relationship, and the investigation must be necessary for the Wellbeing Services County due to a task provided for by legislation, in order to determine the client's need for social services, organise social services, implement applicable measures, and to verify the information provided to the Wellbeing Services County.

In accordance with legislation, the Wellbeing Services County may obtain information on the client's financial situation (e.g., income data) from the national income register.

Information is also obtained with the consent of the client or their legal representative, or under legal grounds, from other actors, such as schools.

In the case of child welfare services, wellbeing services counties are obliged to provide information on the children placed in the wellbeing services county's area in accordance with section 78 of the Child Welfare Act (417/2007).