Data protection

Työttömyyskassa Ote (Unemployment Fund Ote)
Business ID: 0221266-4 
Address: Rautatieläisenkatu 6 (visiting address Kellosilta 7), 00520 Helsinki 
Tel.: 09 4279 9000 (please check the current telephone service hours here) 
E-mail: asiakaspalvelu@ote-kassa.fi  

Please contact us primarily via the Otenetti online service.
 

Arto Pirinen 

tietosuojavastaava@ote-kassa.fi 

Member and payment registry of Työttömyyskassa Ote – Unemployment Fund Ote

The processing of personal data is mainly based on Article 6(1)(c) of the General Data Protection Regulation (EU) 2016/679, i.e. compliance with a legal obligation. This obligation is based on Section 1 of the Unemployment Funds Act (603/1984).

Personal data contained in registers is used for the implementation of benefits administered by the unemployment fund (hereinafter referred to as the Fund) as required by the legislation in force at any given time, such as the earnings-related unemployment allowance referred to in the Unemployment Security Act (1290/2002), for the members of the unemployment fund. In addition, the data is used for providing services to members in matters related to membership and benefits, for the development of the Fund’s operations, and for related activities, such as conducting member surveys. The Fund is unable to process or pay the benefits it administers unless the data subject provides the information necessary for the processing of the benefits.

In addition, we may process personal data on the basis of our legitimate interest (Article 6(1)(f) of the GDPR) in situations involving the investigation of potential misuse, the targeting of communications and marketing, and the creation and processing of statistical data.

The data processed consists of the following types of information relating to members, applicants for membership, and former members:

Content of the filing system

The Fund collects only the data that is necessary for processing members’ benefit applications and for providing and developing member services. The most commonly collected data is listed below. The list is not exhaustive.

Personal data, such as

• Last name, first name

• Personal identity code 

• Any previous personal identity code

• Language
• Postal address, postal code

• Country code

• Telephone numbers

• Email address 

Bank account and member details, such as:

• Date of joining the fund

• Date of resigning the fund; reason

• Unemployment fund membership fee information

• Bank account

• Previous unemployment fund 

• Date of resigning from the previous fund; reason 

Other data, such as: 

• Statements received from the employment authority and the Centre for Economic Development, Transport and the Environment (KEHA Centre)

• Information on a non-disclosure for personal safety

• Information on whether the person wishes to receive notifications by post instead of electronic delivery

• Information on possible guardianship and a power of attorney

Data that affects benefits and payment, such as:

• 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 allowance.

• 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.
• Information to the Employment Fund on transition security entitlement and extended unemployment allowance entitlement, as well as the receipt of unemployment allowance at the age of 63, 64 or 65
• Withholding tax details 
• Monitoring of the employment condition and the related details on wages are accumulated in the filing system.
• Information on the recovery of benefits paid by the Fund, and data and documents related to any recovery proceedings or disputes concerning the termination of an employment relationship.
• Appeals and information related to appeals (including, for example, supplementary statements from the employment authority and decisions issued by the appellate body)

The documents concerning the membership and payments 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).

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. 

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), such as

• The national incomes register (Incomes Register)
• The employment authority and KEHA-centre
• Kela and other unemployment funds
• Digital and Population Data Services Agency
• pension institutions
• from employers, a commissioning party, or another party for whom the work is performed

Information is also collected from parties other than the data subjects, in addition to those mentioned above. Such information includes, for example:

• Trade union and unemployment fund contributions paid to it
• Information on withholding tax obtained from the Tax Administration once a year and via direct transfer at the member’s request
• Work pension data obtained from the Finnish Centre for Pensions for the calculation of employment history
• 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, unemployment fund has a 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.

Calls made to the Unemployment Fund Ote telephone service number are recorded. Calls made by the Unemployment Fund to customers in connection with customer service are also recorded. Customers are informed about the recording of calls. Recordings may be used for internal staff training, for improving the quality of customer service, and for service development. Recordings may also be processed for security reasons, for the prevention of misuse, and for the investigation of legal claims directed at the Fund. The following data is collected in the register in relation to calls: the time of the call, the duration of the call, and the name of the Unemployment Fund official who handled the call.

We monitor customer experience through feedback surveys based on calls made to the telephone service. We collect the person’s telephone number and their response. We may link the respondent and the response.

Personal data is disclosed in situations provided for in Chapter 13 of the Unemployment Security Act to those authorities that are entitled to receive such data. Data may also be disclosed upon request and when necessary on the basis of other legislation. In such cases, data is disclosed only to the extent required by the requesting party for the performance of its statutory duties.

Information on membership, paid benefits, and decisions issued is provided to ministries, the Financial Supervisory Authority, the Finnish Centre for Pensions, the Incomes Register, enforcement authorities, the Employment Fund, and other authorities. The Fund has the right to disclose information obtained in the course of its duties to the employment authority concerning factors affecting the labour policy conditions for receiving unemployment benefits. Data may also be further disclosed to the competent authority for the investigation and prosecution of violations and offences.

Personal data is also processed by suppliers of information systems and services on the basis of an agreement. An agreement has been concluded with the supplier defining the processing of personal data and ensuring compliance with the requirements of the General Data Protection Regulation. The Unemployment Fund may also use other contractual processors who may process personal data for the performance of agreed tasks (for example, conducting member satisfaction surveys).

The Fund may, subject to certain conditions being met, issue decisions automatically when processing follow‑up applications for earnings‑related unemployment allowance that is adjusted to income.

The Fund does not carry out profiling.

As a rule, personal data is not transferred outside the EU or the EEA or to international organisations. Some trade unions representing members that act as processors procure IT or other services from service providers whose operations, sub‑processors, or sub‑processing activities are located outside the EU/EEA. In such cases, personal data processing may take place outside the EU/EEA.

Appropriate safeguards to ensure the rights and freedoms of data subjects in accordance with applicable data protection legislation, such as the EU General Data Protection Regulation (679/2016), have been agreed upon in the contracts concluded between the Fund and the trade unions.

Data retention periods are determined on the basis of the legislation in force at any given time, taking into account the purpose and necessity of the processing. The retention periods are described in the Fund’s internal archiving plan.

All employees of the Fund provide a written confidentiality undertaking. Access to the data contained in the register is granted only to employees who require the data for the performance of their duties, in accordance with separately granted access rights. Paper records are stored in locked premises.

The information systems in which data is stored are technically protected and located in locked and well‑supervised facilities.

The data network is protected by firewalls and other technical security measures.

The systems are protected by individual user IDs and passwords. System use is logged, and the logs are used to monitor the use of data.

Written agreements have been concluded with other parties that process personal data on the basis of a contract, obliging them to protect the data appropriately in a manner proportionate to the risks involved.

We reserve the right to amend and update the notice, for example due to changes in legislation and related practices. The notice in force at any given time is available on our website at www.ote-kassa.fi.

The data subject has the right to access their personal data in accordance with Article 15 of the General Data Protection Regulation. Members of the Fund may review their data directly via Unemployment Fund Ote’s online service Otenetti at https://otenetti.ote-kassa.fi/login/en

Requests to access other personal data being processed should primarily be submitted by sending a message via the online service. If membership has ended and the online service is therefore no longer available, the request must be submitted in another written form. The request must be sufficiently specific, and the data will be disclosed once the identity of the recipient and thus their right to access the data has been adequately verified. Access to data is free of charge once per year.

The data subject has the right to request that the controller rectify inaccurate or incorrect personal data concerning them without undue delay. Members may rectify their own data in Otenetti at https://otenetti.ote-kassa.fi/login/en or by submitting a written request.

The data subject has the right to request the erasure of their personal data in accordance with Article 17. This right is limited by the situations described in Article 17 in which the right to erasure does not apply, such as the Fund’s statutory obligation to retain data for a specified period.

The data subject has the right to request the restriction of processing in accordance with Article 18.

The data subject has the right to receive their personal data and to have it transferred from one system to another in the manner and situations described in Article 20. The Fund uses a jointly agreed method among unemployment funds that enables membership data to be transferred easily from one fund to another.

The data subject has the right to object to the processing of their personal data in certain customer communication situations.

The data subject has the right to lodge a complaint with the supervisory authority (www.tietosuoja.fi) in the manner described in Article 77 if they consider that the processing of their personal data infringes the General Data Protection Regulation.. 

Controller and contact persons

Controller: Unemployment Fund Ote

Contact person responsible for the register: Tuija Häkkinen

Data Protection Officer: Arto Pirinen (tietosuojavastaava(at)ote-kassa.fi)

Purpose of processing and legal grounds

We process the personal data of job applicants in connection with the recruitment process and related activities, such as processing job applications, informing applicants about the progress of the recruitment process, arranging interviews, and assessing professional or personal suitability. The legal basis for processing personal data is the implementation of the recruitment process based on the application you have submitted to us, as well as our legitimate interest.

In certain circumstances and to the extent permitted by applicable law, we may also process personal data for reliability assessments or background checks based on your consent.

If you are selected for the position, the necessary documents generated during the recruitment process will become part of the employment relationship register maintained by Unemployment Fund Ote’s human resources administration.

We do not use artificial intelligence systems in personnel-related decision-making, such as when selecting a person for a position.

Personal Data Processed and Sources of Data

We collect and process only such personal data relating to applicants that is necessary for the processing of job applications and the recruitment process, such as:

• basic information, such as name, home address, email address and telephone number
• information included in your job application and related documents, such as education, previous work experience, degrees, language skills and references
• information collected and processed during the recruitment process, such as data relating to the progress of the recruitment process, notes concerning the application, possible interviews, and references

Personal data may be collected in various ways. As a rule, we collect personal data directly from you, such as your application and its attachments and information provided during a possible interview. To the extent permitted by applicable legislation, we may also collect personal data from other sources, such as public databases or public profiles you have disclosed (for example, a LinkedIn profile), or from referees or similar parties based on your consent.

Disclosure and Transfer of Data

We disclose personal data to third parties only:

• to the extent permitted or required by law
• when our contractual partners process personal data on our behalf and in accordance with our instructions (e.g. HR systems or outsourced recruitment consultants). We always ensure the appropriate and secure processing of your personal data
• when we believe that disclosure of personal data is necessary to exercise our rights, to protect your or others’ safety or legitimate interests, to investigate misuse, or to respond to a request from an authority
• with your consent, to the parties covered by the consent, such as referees

As a rule, personal data is not transferred outside the EU or the EEA or to international organisations.

Retention Period and Data Security

Your personal data is actively processed only for the duration of the recruitment process. After the process has ended, your data is retained for two years from the recruitment decision on the basis of our legitimate interest. The same two‑year retention period applies to unsolicited job applications submitted to us.

Retention based on our legitimate interest is necessary, for example, due to potential future recruitment needs and/or to demonstrate compliance with legislative requirements. In such situations, however, the data will not be processed unless there is a lawful basis for doing so.

Personal data is protected by appropriate technical and organisational measures proportionate to the risks involved. For example, access to the data is granted only to parties involved in the HR process and related processes, and only to the extent necessary for the performance of their duties.

Your Data Protection Rights

You have the right to:

• access your personal data and receive a written copy of the data
• request the rectification of inaccurate or incomplete data
• request the erasure of unnecessary data; however, personal data that is necessary for the purposes described in this notice or that must be retained by law cannot be erased
• object to or request the restriction of the processing of your personal data to the extent required by applicable law
• withdraw your consent to the processing of personal data at any time; after withdrawal, we will no longer process your personal data unless another legal basis exists
• lodge a complaint with the supervisory authority if the processing of personal data is unlawful or otherwise inappropriate and your rights have been violated. The contact details of the supervisory authority, the Office of the Data Protection Ombudsman, are available at www.tietosuoja.fi

You may exercise these rights by contacting the parties listed in the contact details above. Please be prepared to verify your identity.

Updating the Notice

We reserve the right to update this notice. The version in force at any given time is available on our website.

We use cookies on our website. Cookies are small data files that are placed on your computer when you open a website. Cookies are saved with the files used by the browser. Some cookies are used during the session, some for longer. 

Cookies can be divided into four categories: necessary, functional, analytics and marketing cookies. The necessary cookies are mandatory and needed for the web page to function correctly. These cookies do not store the kind of information of users that could be utilized in marketing. 

Functional cookies are used to improve the user’s experience of the page. Analytics cookies collect anonymized information about the page usage used in statistics and site development. Marketing cookies can be for example, used for target marketing.

In addition, the site may have social media extensions that you can take advantage of while logged in to your social media account.

Cookies used on this website and their retention periods

The website uses the Matomo service. These cookies collect anonymous data for analytics purposes. Matomo collects anonymous and statistical information about website usage, such as page views, visit duration, and the type of device used. The collected data cannot be used to identify individual users.

The duration of Matomo cookies varies. Some cookies are automatically deleted when the browser session ends, while others remain stored on the user’s device for a period ranging from a few months up to one year. Cookie retention periods are limited and based on analytics needs.

If you do not wish to accept cookies, you may either disable the use of cookies here or adjust your internet browser settings so that you are notified whenever cookies are being sent to your computer.

Alternatively, you may block the use of cookies entirely. The use of cookies can be restricted or blocked through your internet browser (see your browser’s instructions for more detailed information). Please note that your choices are browser‑specific, meaning that you must make your preferred selections separately for each browser you use.

If you block the storage of all cookies or disable them, some functions of our website may not operate correctly.