Data protection at Elo
Elo’s task is to manage the statutory pension security of employees and entrepreneurs in accordance with the Employees Pensions Act (TyEL) and the Self-Employed Persons’ Pensions Act (YEL), and, for this purpose, manage the accrued funds profitably, safely and responsibly. In order to carry out this task, we need to process personal data. In addition, Elo processes personal data relating to persons belonging to its various stakeholder groups and to its potential customers and business partners.
We ensure the protection of our customers’ privacy and process their personal data in accordance with currently applicable legislation and in a secure manner.
Why does Elo process your personal data?
The collection and processing of personal data is a necessary part of Elo’s statutory duties. Personal data is needed so that insurance contributions can be determined in the correct amount, the amount of pension accrued to insured persons can be calculated, and pension applications can be decided. Legislation also requires the maintenance of various registers, the purpose of which is, among other things, to ensure transparency in the company’s administration or to prevent money laundering.
Contact with representatives of cooperation partners and other stakeholders ensures functional services and dialogue with societal actors in the development of the pension system. In our investment activities, we maintain continuous dialogue with contact persons of existing and potential investment targets so that pension funds are invested productively and securely. In addition, in the marketing of insurance and in connection with the management of insurance, we process the contact details of company representatives and entrepreneurs.
The data collected is also used secondarily to ensure operational continuity, to develop Elo’s own operations and services, and to produce reports.
What personal data of mine does Elo process and for what purposes?
The data processed is determined according to the roles in which you interact with Elo and the purposes for which you do so. Elo collects personal data only to the extent necessary to achieve the objectives of each purpose of use.
As a rule, we obtain data related to earnings-related pension insurance and the administration of pension cover from you yourself, from various authorities, from healthcare operators, and from the employer acting as the TyEL policyholder. Elo’s right to obtain data from sources other than you yourself in these tasks is based on law. We also use commercial operators, such as Suomen Asiakastieto, as data sources, particularly in the processing of personal data related to policyholders, potential customers and investment targets.
More detailed information about the processing of personal data at Elo is available in the privacy statements:
Sale and marketing of pension insurance
Based on legitimate interest, we engage in the sale and marketing of TyEL and YEL insurance through various channels, which is why we process data relating to entrepreneurs as well as company representatives and other responsible persons. The target groups of marketing may include our former or current policyholders or potential customers. We also target digital marketing to selected groups. We comply with the regulations governing direct marketing, and you may object to the use of your data for marketing at any time, in which case we will place a direct marketing prohibition on the contact detail.
In addition to our own customer information systems, we obtain personal data used in marketing from public information sources, such as Suomen Asiakastieto, as well as from our insurance representatives and other partners. The data processed include identification and contact details as well as position in the customer company. When carrying out targeted marketing, we also process, as background data, financial and other information relating to entrepreneurs and companies concerning the nature and scope of the business activity.
For the implementation of marketing, Elo also uses external information system providers and insurance representatives who process personal data on behalf of Elo. Data are not transferred outside the EU/EEA, with the exception of digital marketing, where data are transferred to the USA.
Contact details relating to ended customer relationships are retained by Elo for five years. Background data used for marketing targeting are retained for this purpose for no longer than two years.
Events and stakeholder cooperation
We organise various events as part of customer relationship management or other networking events. Personal data are needed for sending event invitations and for arranging the event or meeting, as well as for monitoring participation. Other stakeholder engagement is also organised, and Elo is in contact, for example, with labour market organisations and other public-interest stakeholders. We may also organise prize draws for selected target groups, for example in connection with events or in appreciation of participation in Elo’s development projects.
We process data on the basis of Elo’s legitimate interest. The data are obtained either from the data subjects themselves or, when selecting the target group, existing data relating to Elo’s customer relationships and stakeholders are used. The data processed include identification and contact details, position in the customer company, and other data provided when participating in the event or prize draw, such as feedback, as well as any recordings that may result from the event. In order to arrange catering for events, we also process data concerning dietary restrictions. Elo also uses external service providers to manage the arrangements, and these providers process personal data on behalf of Elo. Data are not transferred outside the EU/EEA.
Data on those who participated in the prize draw are deleted immediately after the prize has been delivered, and data on those who participated in the event are deleted no later than during the following calendar year.
The provision and administration of TyEL insurance, determining and collecting insurance contributions, and providing related advice are Elo’s statutory obligations. These also include investigating the obligation to insure due to neglect of insurance or in situations open to interpretation. Correspondingly, the employer is obliged to provide the necessary information for arranging the insurance, subject to sanctions. Under the law, Elo is also responsible for collecting neglect fees for failure to insure imposed by the State Treasury. We also keep in contact with TyEL policyholders otherwise for the purpose of managing the insurance customer relationship.
Based on legitimate interest, we also process data concerning insured persons under TyEL and responsible persons of policyholders for the purpose of asserting legal claims where Elo is the injured party in criminal proceedings and for collecting damages awarded to Elo. In this context, we also process data contained in pre-trial investigations and criminal judgments.
The categories of personal data processed concerning contact persons and responsible persons of TyEL policyholders include identification and contact details, information on the person’s position in the company, as well as financial data related to the policyholder’s operations for determining insurance contributions and, for example, in planning collection measures. Data are obtained from the data subjects themselves, our insurance representatives, and public data sources such as Suomen Asiakastieto. Pursuant to the statutory right of access to information, data are also obtained from the Finnish Centre for Pensions and other earnings-related pension providers, the State Treasury, and the Finnish Tax Administration.
We primarily receive data on persons insured under TyEL through the Incomes Register, to which the employer reports earnings forming the basis of the pension. In connection with investigations concerning the obligation to insure, data on earnings forming the basis of the pension are also obtained from the data subject themselves and, as provided by law, from the Finnish Centre for Pensions, the Finnish Tax Administration, and the ELY Centres.
Data are disclosed to the enforcement authority and the debt collection agency (Intrum) for the collection of payments, to courts and authorised debt advisers in debt adjustment matters, and to life insurance companies and various authorities within the scope of their statutory rights to obtain information. As the injured party, we disclose data to the police and the courts. In arranging TyEL insurance, Elo also uses external information system suppliers and, in the administration of the insurance policies, insurance representatives who process personal data on behalf of Elo. Data are not transferred outside the EU/EEA.
Data concerning the insurance of earnings forming the basis of the pension are retained until the person’s death so that, in addition to the statutory retention period, we can ensure the availability of the data in connection with any use of extraordinary remedies and the person’s other requests for clarification. Data concerning representatives of the policyholder are retained for a maximum of 10 years from the end of the insurance or the collection process. Data required for the collection of compensation awarded by a court are retained for no longer than the limitation period under the Enforcement Code, which is a maximum of 20 years from the date the judgment becomes final.
The purpose of the processing is to generate and send the earnings-related pension record and to provide advice related to the record. The processing is based on Elo’s statutory obligation to provide insured persons regularly with information on the earnings that form the basis of the pension, earned income from business activities, social security benefits affecting the determination of the pension, and pension accrual. In addition, Elo’s duties include, among other things, advice concerning pension accrual and the insurance of employment and self-employment.
The categories of personal data processed include identification and contact details as well as other information necessary for providing the record, such as information on the selected delivery channel and the the date on which the previous record was issued. The information content of the record is determined in accordance with the earnings-related pension laws as described above. Information is obtained from the data subjects themselves and, based on the right of access to information laid down by law, from the Finnish Centre for Pensions and other earnings-related pension institutions that have acted as the data subject’s pension insurer.
In generating and sending the earnings-related pension record, Elo also uses external service providers and Posti, which process personal data on behalf of Elo. Data is not transferred outside the EU/EEA.
The record is generated anew each time it is provided, and, apart from a short-term backup copy, no copies of the records are retained by Elo.
Providing YEL insurance, determining self-employed person’s YEL income, and determining and collecting insurance contributions based on that income, as well as providing related advice, are Elo’s statutory obligations. Under the law, Elo is also responsible for collecting negligence fees imposed by the State Treasury. We also stay in contact with YEL-policyholders otherwise as well in order to manage the insurance customer relationship.
The categories of personal data processed include identification and contact details, information on the person’s position in the company, and financial and other data related to entrepreneurial activity that are necessary for determining confirmed income. Data are obtained from the data subjects themselves, our insurance representatives, and public information sources. Pursuant to the statutory right of access to information, data are also obtained from the Finnish Centre for Pensions and other earnings-related pension providers, the State Treasury, and the Finnish Tax Administration.
Data are disclosed to the enforcement authority and to the debt collection agency (Intrum) for the collection of payments, as well as to courts and authorised debt advisers in debt restructuring matters concerning the entrepreneur, and within the scope of various authorities’ statutory rights to obtain information. In arranging YEL insurance, Elo also uses external service suppliers and, in the administration of insurance policies, insurance representatives who process personal data on Elo’s behalf. Data are not transferred outside the EU/EEA.
The legislation requires the data to be retained for at least 10 years after the insurance or collection process has ended. However, the data are retained until the person’s death so that, in addition to the statutory retention period, we can ensure the availability of the data in connection with any extraordinary appeals and the person’s other requests for clarification.
The processing and adjudication of pension and rehabilitation applications, the payment of benefits, and the provision of guidance to applicants and beneficiaries are Elo’s statutory obligations. This obligation includes handling old-age pension, disability pension, rehabilitation and survivors’ pension matters in the manner required by earnings-related pension legislation and administrative law, including appeals relating to benefits and any recovery of unduly paid benefits. In addition to national applications, we also process applications involving work carried out in EU countries and countries with which social security agreements have been concluded.
On the basis of our statutory obligations, we also plan and monitor vocational earnings-related pension rehabilitation and pay expense reimbursements for rehabilitation. On the basis of consent, we maintain contact with the parties participating in and arranging rehabilitation assessments, as well as with Kela and other earnings-related pension institutions.
Discussions on preserving and restoring the work ability of a person receiving disability pension or undergoing rehabilitation may also take place in cooperation with the employer and occupational health care. In such cases, the person’s data are processed only to the extent that the employer has a statutory right to receive the information or the person has personally given consent to the processing.
In addition to the data that the applicant provides in the application or otherwise during the processing procedure, we process data concerning employment and educational history, work ability, family relationships, social security benefits received, and other compensation affecting the amount of pension, as well as data concerning the plans for and success of vocational rehabilitation. Data are obtained from the data subject’s employer and rehabilitation provider, as well as from various authorities, such as the Population Information System and Kela, on the basis of a statutory right to receive information. Data describing work ability and health status may also be obtained directly from various health care providers. In connection with the payment of pension, data received from authorities relating to enforcement and taxation are processed. Failure to provide data in the application may, for example, lead to rejection of the application.
In the processing, we use external information system suppliers acting on Elo’s behalf. With the person’s consent, data are disclosed to parties participating in the planning and organisation of rehabilitation. In rehabilitation, we also use external service providers acting on our behalf. Payments are transmitted through banks operating in Finland, in which connection personal data are transferred to the banks. Data are not transferred outside the EU/EEA, except for certain processing carried out on Elo’s behalf by certain information system suppliers and the processing of pension applications relating to work carried out in the United Kingdom.
The data are retained until the person’s death so that, in addition to the statutory retention period, we can ensure the availability of the data in connection with the use of any extraordinary means of appeal and the person’s other requests for clarification.
In connection with the management of work disability risks, personal data are processed that were originally collected in connection with the handling and decision-making of applications for disability pension and rehabilitation, as well as in connection with earnings-related pension insurance. Based on these data, Elo’s risk assessment of its insurance portfolio is formed, and the data are utilised in the management of work disability risks of Elo’s client companies, in the development of work ability management, and in the risk-based targeting of measures related to the management of work disability risks. We also carry out various studies and research on work disability risks to support our operations. For these purposes, the data are processed in aggregated form, and no individual person can be identified in connection with the services or reports provided.
Work disability risk assessments and information and guidance intended to support risk management may also be carried out in a targeted manner for named employees of certain Elo client companies. In such cases, we process identifying and contact details of these selected target groups notified by the client company, as well as data on the use of the services collected from the data subjects themselves, on the basis of Elo’s legitimate interest. Elo’s legitimate interest is then based on identifying and managing the risks in its insurance portfolio.
Personal data collected in the management of work disability risks are not disclosed further. In processing the data, we use external system suppliers acting on behalf of Elo. The data are not transferred outside the EU/EEA.
The data are retained for as long as they are relevant for identifying work disability risks and targeting measures, taking into account the data minimisation requirements.
We collect data on interactions that take place in our various customer service channels.
Authenticated customer service interactions in Elo’s online services and by phone
In online services that require login, we require strong authentication to ensure that only persons entitled to do so can access confidential data and act on behalf of the policyholder. We also use strong authentication in telephone services. The processing of personal data related to authentication and user access management is therefore based on Elo’s statutory obligation, and without the data required for strong authentication it is not possible to use these services.
The categories of personal data processed include identification and contact details as well as information on the right of representation. The policyholder may grant rights of representation to persons of its choosing, and otherwise the data is obtained from the individual themselves, as well as through the authentication service used and Suomen Asiakastieto.
Elo uses external information system suppliers in the provision of its services. Data is not transferred outside the EU/EEA area.
The data is retained for the duration of the online service agreement or for 5 years after the termination of the insurance agreement. Data relating to electronic identification carried out by phone is deleted immediately after the service event.
Recording of telephone calls, chat conversations and other customer communications
In chat and telephone services, data is collected for the documentation of customer service and sales situations, the development of operations, and the safeguarding of the customer’s legal protection. Recordings are used primarily to verify the service event, and the legal basis for processing is Elo’s legitimate interest. In addition, recordings and customer communications are analysed to improve customer understanding and to enable service development. A person’s identification and contact details can, as a rule, be linked to the recordings.
Elo uses external information system suppliers in the provision of its services. Data is not transferred outside the EU/EEA area.
At the beginning of the call, you may inform the customer service representative if you do not want the conversation to be recorded. Call recordings are retained for three months.
Monitoring the use of electronic services
We collect behavioural data on the use of our various electronic services so that we can offer personalised content and recommend our services more effectively according to our customers’ current needs. We analyse and use information generated from the use of electronic communications and websites so that we can provide our customers with interesting and targeted information about Elo’s services, inform them of current matters, and market our services to our insurance and pension customers.
The processing is based partly on consents given for the use of cookies and partly on cookieless technologies and Elo’s legitimate interest in developing and targeting its services. You can read more about this on the page Cookies. The development of Elo’s own operations is important so that we can offer our customers competitive services and ensure the high quality of our customer service.
On the basis of our legitimate interest, we collect customer feedback both after individual customer contacts and, for example, from participants in events organised by Elo and from our various stakeholder groups. Elo also has a customer panel, in which the personal data of participants are processed on the basis of their consent. The purpose of the processing of personal data is to send surveys and to ensure and develop the quality of the customer experience, as well as to obtain customer insight in order to improve and develop services and to strengthen customer retention based on the feedback received.
Elo uses external service providers to collect feedback, and these providers process personal data on behalf of Elo. The data are not transferred outside the EU/EEA.
Feedback is retained for a maximum of three years for up to three years from when the survey was conducted. Direct personal data in the survey data are pseudonymised for the analysis of responses within one month after the survey has ended.
Prevention of money laundering and terrorist financing and compliance with sanctions
Elo complies with legislation on the prevention of money laundering and terrorist financing, which requires the identification and verification of Elo’s business partner and the representative of the business partner, as well as sufficient knowledge of the customer relationship and business activities. In addition, sanctions regulation obliges Elo to identify its business partners and their representatives. Data is obtained from the data subjects themselves and from contractual partners, but also from various public sources, such as Suomen Asiakastieto, the Dow Jones service, and registers in other countries corresponding to the trade register.
We use external system suppliers acting on behalf of Elo in the processing. Data is not transferred outside the EU/EEA, except for processing carried out on behalf of Elo by certain system suppliers. Data is retained for a maximum of 10 years from the end of the contractual relationship.
Monitoring of business transactions with related parties
Elo’s obligation to maintain a related party register and the persons belonging to the sphere of related parties are defined in the Act on Pension Insurance Companies. The register collects the persons’ identification data, the relationship to the related party, business transactions carried out with related parties and their counterparties, as well as entities in whose administration the person serves. The personal data processed is obtained from the Finnish Patent and Registration Office and from the data subject themselves. The register is public, except for exceptions provided by law. The data entered in the register must be retained for five years from the entry of the information.
Compliance with data protection regulation
Personal data of persons in contact with Elo is also processed in order to fulfil their rights under the General Data Protection Regulation and Elo’s obligations (such as the fulfilment of the data subject’s rights or other communication with the data subject, the handling of personal data breaches, and responding to complaints submitted to the Data Protection Ombudsman). The data is obtained from the data subject themselves and may be disclosed to the competent authorities within the framework of rights and obligations under the General Data Protection Regulation. Data is retained for 16 years.
Notifications to the Transparency Register
The purpose of the processing is to report on Elo’s societal influence activities and to maintain, for that purpose, a register of persons who have been the subjects of lobbying activities. The processing is based on Elo’s statutory obligation to submit notifications to the Transparency Register as provided in the Act on the Transparency Register. In addition, the data is used for Elo’s internal monitoring and reporting of activities. Data is not collected in connection with Elo’s ordinary dealings with authorities or when Elo participates, for example, in working groups appointed by an authority or required by law, or in hearings organised by ministries.
The content of the activity notification is defined in detail by law. The categories of personal data processed include identification data of persons who have been the targets of Elo’s influence activities as defined in the Act on the Transparency Register, data related to contacts, and marketing and representation expenses related to the influence activities. In addition, identification data of the Elo representative who participated in the influence activities is collected.
The data is obtained from the data subjects themselves and is disclosed by virtue of law only to the National Audit Office of Finland. Elo also uses external system suppliers to maintain the register, and they process personal data on behalf of Elo. Data is not transferred outside the EU/EEA.
The activity notification is submitted twice a year, and the data is retained by Elo for one year from the submission of the notification.
The management of the recruitment process, such as processing job applications, providing information about the process, arranging job interviews, and processing open applications, is necessary for taking steps prior to entering into a contract. In connection with the assessment of suitability, reliability, and eligibility, the processing is based on the consent provided.
We process applicants’ identification and contact details as well as information contained in the application, for example regarding education and work experience. Applications may also include personal data relating to referees, and during the recruitment process the applicant may, if they so wish, provide other information about themselves as well. Depending on the position applied for, the applicant may be requested to participate in suitability assessments or to grant permission for a credit check, security clearance, or drug test, the results of which are processed as part of the recruitment process.
Information is obtained from the data subject themselves and from the referees named by them. Credit checks are carried out through Suomen Asiakastieto, and the Finnish Security and Intelligence Service conducts security clearances. We use external service providers for suitability assessments and drug tests.
Information is disclosed to the above-mentioned parties to the extent necessary for the performance of their duties. Information is not transferred outside the EU/EEA.
The information is retained for two years from the recruitment decision, in accordance with employment legislation. Regarding the results of credit checks, drug tests, and security clearances, only information on for whom they were carried out, when they were carried out, and the outcome is retained. A security clearance is retained for its period of validity, i.e. 5 years. The retention period for suitability assessments is 2 years. References are deleted annually. Open applications are retained until the end of the calendar year following the submission of the application. Applications of applicants who were not selected are retained for 13 months on the basis of legitimate interest.
Data is processed in the implementation of real estate transactions, in the administration of lease agreements and tenancy relationships, and in offering real estate properties as well as in communication and negotiations with potential customers.
Personal data is processed in the implementation and management of corporate financing agreements and in related communications, as well as in establishing the background of the persons responsible for the borrower customer. The background of responsible persons connected with financing opportunities and of beneficial owners of corporate entities is also examined for the purpose of making a loan offer and processing a loan application.
Data is processed in the evaluation of investment targets, in assessing potential cooperation relationships and maintaining communication, and in establishing the background of key persons. The processing of investment applications and offers, the implementation of agreements, and the monitoring of investments also require the processing of personal data. The procurement of services related to Elo’s investments, the provision and implementation of services on a contractual basis and related communications, as well as measures related to the conclusion of an agreement, also involve the processing of personal data.
The processing is based on Elo’s legitimate interest in carrying out investment activities that form part of its insurance business, or it is necessary for the performance of agreements.
Data is also processed for the appointment of members of governing bodies and for managing communication during the appointment. We also maintain a list of potential members of governing bodies in order to appoint persons to the governing body of another company when Elo has a representative on the nomination committee. This processing is based on Elo’s legitimate interests in managing its investments.
The categories of personal data processed include identification and contact details, as well as information related to the investment target and the person’s position in it. Data is obtained not only from the data subjects themselves, but also from client entities and other contractual and cooperation partners and service providers. We also use Suomen Asiakastieto, the Finnish Patent and Registration Office and corresponding foreign registry authorities, as well as the Dow Jones Risk and Compliance system, as sources of information. Failure to provide the data may result in Elo being unable to carry out the intended investment.
Data is disclosed to external parties only in cases where the recipient has a statutory right to receive data from Elo or, in exceptional cases, with the data subject’s consent. Elo also uses service providers in its investment activities and support functions, who process personal data in order to provide their services to Elo. These include brokers for the leasing of premises, property managers, advisory and brokerage firms, providers of legal and tax services, providers of investment services and fund services, and providers of web and system maintenance services. Elo also discloses data to KTI Kiinteistötieto Oy for the purpose of carrying out market research in the real estate business. As a rule, data is not transferred outside the EU/EEA.
As a rule, the data is deleted no later than 10 years after the end of the transaction. Data concerning persons related to potential investment targets is usually retained for three years.
Elo’s service providers’ contact persons
When procuring services related to Elo’s operations, in the production and implementation of services in contractual relationships and the related communication, as well as in connection with measures relating to the conclusion of a contract, we process data concerning the representatives and service providers’ contact persons. The processing of this data is based on Elo’s legitimate business interest in procuring services also from external operators. Personal data is also needed for the payment of fees and expense reimbursements related to the performance of contracts. Incomplete data may lead to a contract not being concluded or reimbursements not being paid.
Data is obtained from the data subjects themselves and from the company they represent, as well as from Suomen Asiakastieto. The categories of personal data processed include identification and contact details, as well as data concerning the service provider and billing.
In the processing, we use external IT system providers acting on behalf of Elo. Data is not transferred outside the EU/EEA.
The data is retained for 10 years after the end of the contractual obligations.
Elo’s tenants
Before the contract is concluded, data is processed to investigate the backgrounds of rental applicants for tenant selection. Personal data is also processed to ensure the safety of the properties and the tenants. In these situations, the processing is based on Elo’s legitimate interest in ensuring the proper use of the rental property.
Data is processed for the conclusion and performance of the lease agreement, as well as for the management of the tenancy and related communication. Data is also needed for the handling of any rental disputes. In such cases, the processing is based on the performance of the contract. Incomplete data may lead to the contract not being concluded.
The categories of personal data processed include identification and contact details, data related to financial standing and solvency, and data concerning the lease agreement and the rental property. Data is obtained from the data subjects themselves and from Suomen Asiakastieto in connection with credit checks.
In renting out apartments and carrying out its support functions, Elo also uses trusted service providers that process personal data on behalf of Elo. These include brokers for premises rentals, property managers and other service providers in the real estate business that have a contractual relationship with Elo. Elo also discloses data to KTI Kiinteistötieto Oy for the implementation of real estate market research. Data is not transferred outside the EU/EEA.
As a rule, the data is deleted no later than 10 years after the end of the lease agreement.
If you have questions about your tenancy concerning matters other than those described in this privacy notice, please contact the contact person for your tenancy.
The collected data may also be used for other purposes in a manner compatible with the original purposes of use. This means, for example, that:
- we analyse the use of services, the frequency of use, service channels and customers’ contacts with us in order to better understand our customers’ wishes and needs and to develop the functionality of our services, clarify processes, improve the customer experience and strengthen customer engagement
- we use the collected data in statistical analyses, studies and modelling through which we identify, among other things, phenomena and development needs relating to the use of services and benefits, customer relationships and risks of work disability, and we use this information to improve and enhance our operations
- we seek to anticipate the development of customer relationships and to adapt customer-specific measures accordingly
- we carry out various quality assurance measures, controls and cross-checks in databases in order to ensure that the data is accurate and up to date and that it is transferred correctly between systems
- we may, to a limited extent, use the data for the development, testing and deployment of information systems in order to ensure their secure and reliable operation
- we produce statistics and analyses that are used in the planning, management and reporting of Elo’s own operations
- we report on our operations to the Finnish Centre for Pensions and the Financial Supervisory Authority
- we produce statistical reports to support TyEL policyholders in managing the risk of work disability; these reports are based on data collected and generated in connection with insurance activities and pension decision-making
For these purposes, the data is processed primarily in aggregated, anonymised or pseudonymised form whenever possible.
To whom does Elo disclose or transfer my data?
Data related to earnings-related pension insurance and benefits is confidential. Elo may disclose personal data of pension and insurance customers only with the person’s consent, or where the person has authorised a third party to handle matters on their behalf, and where the recipient has a statutory right to obtain data from Elo. Such recipients include, among others, various social security authorities and the tax administration. The employer of the insured employee also has the right to obtain information on granted pensions for purposes specified in more detail in the Employees Pensions Act.
In its operations, such as tasks related to the maintenance and development of information systems and the administration of insurance, Elo uses external service providers, which then process personal data on behalf of Elo. The service providers are mainly located in the EU/EEA area, but in the case of some of them, data is also processed in other countries. In transfers of data outside the EU/EEA, the existence of appropriate transfer mechanisms is ensured and, in addition, personal data is protected wherever possible, for example by pseudonymisation.
How is my data protected?
The most important principle of Elo’s information security is responsible operation. The objective of information security is to safeguard the reliability, usability and availability of the data processed at Elo and to prevent confidential data from falling into the wrong hands.
Information security is an essential part of the quality of Elo’s operations and services, overall security, and the daily processing of data. Our information security policy defines the roles and responsibilities for ensuring information security. We have invested in our processes so that data protection risks can be assessed in advance and avoided, and we continuously develop data protection and information security. Elo’s entire personnel is trained in data protection and information security matters, and we have appointed a Data Protection Officer.
We also require a high level of information security from our service suppliers and conduct information security audits of information systems, as well as maintain close cooperation with our various ICT service suppliers and information security partners. As a company critical to security of supply, Elo also cooperates with various authorities and takes cybersecurity best practices into account in its operations.
Profiling and automated decision-making
We issue automated decisions regarding pensions other than discretionary pensions and regarding YEL insurance. Automated decision-making is based on predefined rules and, where necessary, an application is referred for human handling. Once you have received an automated decision, you have the right to demand that the application be reconsidered in a non-automated procedure and to appeal the decision. You can read more about automated decision-making at Elo on the website General notifications and implementation decisions.
In order to ensure quality and a consistent decision-making practice, assistive profiling may be used to support the decision-making work relating to disability pension and rehabilitation decisions. Profiling is based on the data of the matter being processed and on decision statistics. Automated decisions are not made in relation to these benefits on the basis of profiling.
Artificial intelligence may be used in assistive tasks to support processes. However, administrative decisions are not made by means of artificial intelligence.
What rights do I have?
You have the rights to your personal data that are provided for in data protection legislation. The scope of these rights varies depending on the basis on which Elo processes your data. For example, as a rule there is no right to have data collected for Elo’s statutory duties erased, because other legislation requires Elo to retain this data for a specified period. The justified rights of other persons or companies, such as privacy protection or trade secrets, may also limit your rights.
The right of access means that you have the right to know what personal data Elo processes about you. You may request to see this personal data and receive a copy of it, as well as information on the purposes for which and the manner in which your personal data is processed. Some of the data can also be reviewed directly by you in our online services. You may exercise this right, for example, to ensure that your own data is up to date and that it is processed lawfully.
However, the right of access may be exercised only where the disclosure of data does not endanger the privacy of others or trade secrets.
The right to rectify data means that you have the possibility to request the correction of personal data concerning you processed at Elo if the data is incorrect, outdated or incomplete. You may request rectification, for example, if you notice that your address has changed or some other data is inaccurate. Some of the data can also be managed by you in our online services.
This right may always be exercised where there are clear errors or omissions in the data. However, it cannot be exercised if there is another lawful basis for keeping the data unchanged, such as a statutory obligation or the rights of another person that prevent the change from being made. For example, if data is needed for official duties, it may not necessarily be changed or removed despite your request.
By rectifying incorrect data, you can ensure that the data about you held at Elo is up to date and correct, and that, for example, accurate data about you is used as the basis for decisions. This also enables us to provide you with the right services at the right time.
The right to erasure of data means that you may request Elo to erase personal data relating to you in certain situations. This right may be exercised, for example, where the data is no longer needed for the purpose for which it was originally collected, or where you do not want your data to be retained after the customer relationship has ended.
However, there are situations where Elo cannot erase your data despite your request. These include, for example, statutory obligations that require data to be retained for a certain period. In such cases, the processing of data continues within the limits permitted by law. If, on the other hand, the processing of some of your data is based on your consent, you may withdraw your consent at any time, after which we will erase the data in question.
The right to restrict processing means that you may request Elo to temporarily restrict the processing of your personal data. In such a case, Elo may store your data, but may not use it for any other purpose. You may exercise this right, for example, where you suspect that your data is inaccurate and its accuracy is being verified. Restriction of processing may also be necessary if you object to the processing of data or if the processing of data is unlawful but you do not want your data to be erased.
This right cannot be exercised where the processing of data is based on statutory obligations.
Office of the Data Protection Ombudsman
P.O. Box 800
FI-00531 Helsinki
www.tietosuoja.fi