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Työttömyyskassa – Teachers’ Unemployment Fund



 Rautatieläisenkatu 6, 00520 Helsinki, Finland

Other contact information  tel. +358 (0)9 229 44 100

Data protection



Kari Lehtinen 

Contact information

Filing system

Member and
payment registry of Opettajien Työttömyyskassa – Teachers’ Unemployment Fund

Purpose and
legal basis for processing

The processing
of personal data is based on point c of Article 6(1) of the General Data
Protection Regulation (EU) 2016/679. The obligation is based on Section 1 of
the Act on Unemployment Funds (24 August 1984/603).

The data in the
personal data filing system is used by the unemployment fund for providing
benefits for its members as decreed in current legislation, such as
earnings-related allowance as referred to in the Act on Unemployment Security
(1290/2002) and job alternation compensation as referred to in the Act on Job
Alternation Leave (1305/2002, as well as for providing services to Fund
members in matters pertaining to their membership and benefits.

The Teachers’
Unemployment Fund (Fund) cannot pay the benefits
processed by the Fund unless the data subject provides the data necessary for
their processing.

Description of
the categories of data subjects and the categories of personal data, as well
as data sources to the extent that the data has not been obtained directly
from the data subject.

Content of the filing

The Fund only collects the data required for processing members’
benefit applications: Such data includes:

Personal data

  •   Last name, first name
  •   Personal identity code
  •   Any previous personal
    identity code
  •   Language
  •   Postal address, post code
  •   Country code
  •   Telephone numbers
  •   Email address

Bank account and member

  •   Type of membership
  •   Date of joining the fund
  •   Date of resigning from the
    fund; reason
  •   Bank account
  •   Previous unemployment fund
  •   Date of resigning from the
    previous unemployment fund; reason

Other data

  • The name and number of the
    member’s local Employment and Economic Development Office (TE Office), as
    well as the statement code and additional information field of the statement
  •  Free-form field for any
    additional information
  •  Information on any power of
  •  Permission to use electronic
    letters and internet services

Data that affects benefits
and payment

  • Salary on which the
    allowance is based and amount of allowance.
  • The member’s salary income,
    adjustment period and any social benefits that affect the amount of the daily
  • Dates of birth of the
    member’s children and dates of birth of the children of a partner who lives
    at the same address. For the payment of any child increase.
  • The Fund is obliged to
    forward certain collections from the benefits paid by the Fund (e,g, debt
    recovery and recovery for the Social Insurance Institution (Kela)).
  • Maximum payment period
    counters and the accumulation of days. 
  • The benefits paid and
    decisions made are accumulated in the filing system, which also contains data
    on financing contributions.
  • Annual accumulation
  • Unemployment Insurance Fund.
  • Monitoring of the employment
    condition and the related details on wages are accumulated in the filing
  • The filing system contains
    data regarding a benefit that the Fund is recovering or has recovered, as
    well as its amount.
  • If a Fund member has
    appealed a decision that he or she has received, this will be entered in the
    filing system.
  • The documents concerning the
    member are collected in the filing system. 
    The documents may have been provided by the member personally or by an
    external party (e.g. employer, Kela).
  • Data collected from the
    telephone service includes time of call, duration of call and the code of the
    processor who took the call. The calls made to the telephone service number
    are also stored.
  • Members can contact us and
    change their contact information via the online service.  Contacts and changes to contact details are
    stored in the filing system. Letters sent by the Fund to its members are also
    accumulated in the filing system.

Situations in which data is
collected from others than the data subjects

  • Membership data is collected
    from the member registry and the member’s own reports.
  • The TE Office provides the
    Fund with labour policy statements concerning the member.
  • Tax information is obtained
    from the Tax Administration once a year.
  • Details on decisions from

Data sources

Data is
regularly obtained for the filing system from membership and benefit
applications submitted by members and from the authorities referred to in
Chapter 13, Section 1 of the Act on Unemployment Security (1290/2002).

  • From government and
    municipal authorities and other public sector organisations;
  • The
    Finnish Centre for Pensions, pension and insurance companies, and pension
  • From
    employers, clients or other commissioners of work, unemployment funds, employer’s
    funds and training service providers or other educational institutes referred
    to in the Act on Public Employment and Business Service; or
  • Other
    organisers of employment promotion measures.
  • From the
    labour force authorities, labour policy statement referred to in Chapter 1,
    Section 4(3) of the Act on Unemployment Security;
  • From penal
    institutions, information on the beginning and end of a penalty. The penal
    institution must provide the information immediately when a person is
    admitted into a penal institution.
  • Kela must
    inform the relevant unemployment fund if the recipient of an earnings-related
    allowance or their spouse is granted child home care allowance as referred to
    in the Child Home Care and Private Day Care Allowance Act.
  • Notwithstanding
    the provisions on confidentiality and other restrictions on access to data,
    Kela and unemployment fund have to right to obtain the necessary details on
    the income of recipients of unemployment benefits from the Tax Administration
    free of charge in order to investigate the misuse of unemployment benefits.

Groups of
recipients of personal data to whom personal data has been disclosed or will
be disclosed.

Data is
disclosed in situations provided for in Chapter 13 of the Act on Unemployment
Security to the authorities who are entitled to obtain the data.

the provisions on confidentiality and other restrictions on access to data,
the unemployment fund has the right to disclose information obtained in
performing its duties to labour force authorities on matters that affect the
labour policy requirements for the payment of unemployment benefits.

the provisions on confidentiality, data may further be disclosed to the
relevant authority in order to investigate offences and crimes and for the
purposes of prosecution.

Data is also
disclosed to the Financial Supervisory Authority in accordance with Chapter
13 of the Act on Unemployment Funds.

  • To processing
    system suppliers and other subcontractors (IT service providers, the Union as
    the filing system maintainer for Union members), who may process data on a
    contractual basis and only to the extent required for the performance of the

Transfer of
personal data to a third country or an international organisation.

No data will be
transferred outside the EU or EEA or to international organisations.

Data retention

The data
retention periods are defined according to the currently valid laws, taking
into account the purpose and necessity for processing. The data retention
periods are described in the Fund’s internal archive creation plan.

Description of
technical and organisational security measures.

Each Fund
employee signs a written non-disclosure commitment, and the data in the
filing system will only be used by employees who need the data in their work
on the basis of separately granted user rights. Manual materials are stored
in locked premises. 

The data systems
in which the data is stored are technically protected and located in locked
and well monitored premises.

communications network is protected with firewalls and other technical

The systems are
protected by unique user IDs and passwords. Log data is stored of all use of
the systems and is used for monitoring the use of data.

Data subjects’
right to access data pursuant to Article 15.

Data subjects
have the right to check their own personal data. Data subjects may check
their personal data directly via the Openetti system.  

You can request
to review your personal data processed by the Fund by sending an email to or with an Openetti
message, which will provide further instructions. The request must be
sufficiently detailed. One review per year is free of charge.

The right to the
rectification and erasure of data, the restriction of processing and data
portability pursuant to Articles 16,17, 18 and 20.

The data subject has the
right to demand that the controller rectifies any inaccurate personal data
concerning the data subject without undue delay.  You can make the request in the Openetti
service at  or by email at 

  • The data subject has the right to demand the erasure of data
    concerning him or her in accordance with Article 17. This right is restricted by situations
    described in Article 17 in which the right to erasure is not applied, such as
    in the case of the Fund’s statutory obligation to retain certain data for a
    certain period.
  • The data subject has the right to demand the restriction of processing
    in accordance with Article 18
  • The data subject has the right to have the personal data concerning
    him or her transmitted directly from one system to another in the manner and
    situations described in Article 20. 
    The Fund uses the method jointly agreed between Funds to facilitate
    the transfer of membership from one fund to another.

Right to withdraw
consent and right to lodge a complaint with a supervisory authority


  • If the processing is carried out on the basis of consent as referred
    to in Article 6, the data subject has the right to cancel their consent
    pursuant to paragraph 3 of the Article. As a general rule, the Fund does not
    process personal data on the basis of consent, so this right does not apply.
  • Data subjects have the right to lodge a complain with a supervisory
    authority in the manner described in Article 77, if they consider that the processing of personal data
    relating to him or her infringes the data protection regulation.