Pilke Daycare Centres 26 January 2018
1. Description
Privacy Policy of the customer register
2. Register information
Controller: Pilke päiväkodit Oy (Pilke Daycare Centres)
Business ID: 1840113-6
Contact person for register issues:
Data Protection Officer
Mira Tuohenmaa-Virtanen
Tel. +358 40 905 3002
mira.tuohenmaa-virtanen@pilkepaivakodit.fi
3. Purpose of the register
The personal data stored in the register is used for communication and maintaining the customer relationships of Pilke Daycare Centres and its subsidiaries. The data is also used for the production of services, the preparation of service contracts, invoicing, marketing and the preparation of early childhood education and care curricula.
4. Data contained by the register
Only data that is necessary for the register’s purpose of use is stored in the register. Pilke Daycare Centres’ customer register may contain the following data on daycare centres’ customers (in this policy, ‘customer’ refers to both the children and the holders of parental responsibility):
Name
Address
Telephone number
Email address
Customer history
Personal identity code
Contact information of the persons who may pick up the child on behalf of the guardian
Children’s allergies and long-term illnesses
5. Data sources and legal basis for processing
The processing of personal data is based on a customer relationship, the customer’s consent or commission, or another appropriate connection. The register data derives from information provided by the customer. Pilke Daycare Centres, 26 January 2018, 2 (4) PRIVACY POLICY
6. Regular disclosure of data
In certain situations, Pilke Daycare Centres may transfer personal data to third parties. In that case, the third parties act as processors of the personal data. Data is transferred to third parties for the provision of, for example, marketing and IT services.
Pilke Daycare Centres may also transfer or disclose personal data to its group companies or a successor as a consequence of, for example, a corporate transaction, business disposal, merger, demerger, bankruptcy or liquidation.
Pilke Daycare Centres shall, under all circumstances, contractually ensure that the personal data is retained and processed in an appropriate and secure manner.
The data may also be disclosed to authorities as required by valid legislation.
7. Transfer of data outside of the EU or the EEA
Pilke Daycare Centres shall not transfer data outside of the EEA with the exception of circumstances permitted by law.
8. Principles of register protection and data retention period
The data stored in the register are always processed confidentially, and access to the data is restricted to only the necessary personnel. The register is located and its data stored on a secure server. When required, electronic data transfer is carried out using an encrypted and protected connection.
Non-electronic information is stored in locked and/or supervised facilities. The data is retained only as long as required by its purpose of use. At the expiry of the retention period, the data is destroyed in a secure manner.
When using third-party services referred to in Section 6, Pilke Daycare Centres and the third party conclude a contract on the processing of personal data where the third party undertakes to comply with the General Data Protection Regulation’s requirements on, for example, personal data processing and data security. If early childhood education and care is implemented as a purchased service or with a service voucher, documents are stored in compliance with the municipality’s instructions.
9. Rights of the data subject
Right of inspection
The data subject has the right to inspect their personal data processed by Pilke Daycare Centres. The data subject may request Pilke Daycare Centres to explain which personal data the company processes and to provide the legal basis for the processing.
Right of rectification
The data subject has the right to demand rectification or supplementation of false, inaccurate, incomplete, obsolete or unnecessary data by contacting Pilke Daycare Centres.
Right to erasure
The data subject has the right to request Pilke Daycare Centres to erase their personal data from its systems. Pilke Daycare Centres shall erase the data in the absence of a justified reason not to erase the data, such as complying with Pilke Daycare Centres’ legal requirements. The data may not be removed immediately from all of Pilke Daycare Centres’ backups or similar systems.
Right to object
The data subject has the right to request restrictions for the processing of their personal data if the data is used for purposes other than the provision of Pilke Daycare Centres’ services or the fulfilment of legal requirements. The data subject may also object to the future processing of their personal data even if the processing is based on a permission provided earlier. Objecting to the processing of personal data may lead to restricted opportunities to use the services provided by Pilke Daycare Centres.
Right to restriction of processing
The data subject has the right to request Pilke Daycare Centres to restrict the processing of their personal data. Requesting restricted processing of data may restrict the data subject’s opportunities to use Pilke Daycare Centres’ website and services.
Right to data portability
If Pilke Daycare Centres’ processing of personal data is based on the data subject’s consent, they shall have the right to receive their personal data in a structured, commonly used format in order to transmit the data to another controller.
The data subject may exercise their rights by sending email at mira.tuohenmaa-virtanen@pilkepaivakodit.fi or by contacting the daycare centre manager. When making a request, the data subject shall primarily use the email address registered in Pilke Daycare Centres’ register. The reply shall primarily be sent to the registered email address.
In addition to the aforementioned rights and other rights of the data subject, they have the legal right to lodge a complaint with a supervisory authority, in particular in the EU member state of their permanent residence or work or where the alleged infringement of the General Data Protection Regulation occurred. In Finland, this supervisory authority is the Data Protection Ombudsman.
10. Changes to this register description
Pilke Daycare Centres may occasionally make changes to this Privacy Policy without prior notice. However, if changes are made to this Privacy Policy, and the processing of personal data is based on the data subject’s consent, Pilke Daycare Centres shall notify all registered users of the matter using the email addresses they have provided or otherwise in writing.
