2 April 2024

D/211/04.13.01.04/2024

1 (4)The EU General Data Protection Regulation, Article 14

Communication on the collection and storage of your personal data in the FinnishTransparency Register
This is a communication in accordance with Article 14 of the EU General Data Protection Regulation(GDPR) on the collection and storage of your personal data in the Finnish Transparency Register. This
communication does not require any action from you. The Finnish Transparency Register is a registerestablished by the National Audit Office of Finland under the Finnish Transparency Register Act(430/2023). The information stored in the Register relates to long-term and professional lobbying orlobbying consultancy that targets Parliament or the ministries.
Lobbying refers to communicating with a lobbying target on one's own account with the aim of
influencing the preparation and decision-making in a matter by promoting a certain interest orobjective. Lobbying consultancy refers to such professional activities where lobbying is carried out onbehalf of a client or where a client is provided with support in lobbying. (Finnish Transparency Register
Act (430/2023), section 2)
According to section 2 of the Finnish Transparency Register Act (430/2023), you are a lobbying target
to be disclosed to the Register. Lobbying targets include:
1.
2.
3.
4.

Members of Parliament, parliamentary assistants and the staff of parliamentary groups
ministers, special advisers to ministers and state secretaries appointed for ministers' term ofoffice
Parliamentary Officeministries and rapporteurs appointed by them.

The collection of your personal data is based on section 8(4) of the Finnish Transparency Register Act(430/2023). According to it, lobbying targets shall be specified in the disclosure of activities in such amanner that the person is named in the case of:••••••Members of Parliament
ministers
state secretaries and special advisers appointed for Ministers' term of office
the Secretary-General and Deputy Secretary-General of Parliament
permanent secretaries, permanent under-secretaries and directors-general of ministries
rapporteurs appointed by ministries.

The name of the parliamentary group is given for the parliamentary assistants and the staff of theparliamentary groups.
The name of the department and unit is given for communication with other public officials of theministries.
As for communication with other public officials of the Prime Minister's Office, information is given on
the committee, department and unit or other corresponding part of the organisation.

NATIONAL AUDIT OFFICE OF FINLANDPORKKALANKATU 1 | PO BOX 1119 | FI-00101 HELSINKI, FINLAND
TEL. +358 (0)9 4321 | WWW.VTV.FI

2 (4)

Below is a list of the information in accordance with Article 14 of the EU GDPR on the Transparency
Register and on the processing of the personal data collected and stored for it.
The EU General Data Protection Regulation, Article 14Information to be provided where personal data have not been obtained fromthe data subject
Paragraph 1(a)the controller's (i.e. the registrar's)
National Audit Office of Finland (NAOF)
contact information
Porkkalankatu 1
FI-00101 Helsinki, tel. +358 (0)9 4321
kirjaamo@vtv.fi(b)
the contact details of the data
Mari Tölli
protection officer
National Audit Office of Finland (NAOF)
Porkkalankatu 1
FI-00101 Helsinkitel. +358 (0)50 532 9719
tietosuojavastaava@vtv.fi(c)the purposes of the processing for
The purpose of processing the personal data is towhich the personal data aremaintain a transparency register as referred to in theintended as well as the legal basis for Finnish Transparency Register Act (430/2023).
the processing
The right of the National Audit Office to process
personal data is based on the Finnish Transparency
Register Act (430/2023) and points (c) and (e) ofparagraph 1 of Article 6 of Regulation (EU) 2016/679
of the European Parliament and of the Council(General Data Protection Regulation).
(d)the categories of personal data
The data stored on lobbying targets in the Finnish
concerned
Transparency Register include the workplace, title
and name as well as the email address as contactinformation.
(e)
the recipients or categories ofThe workplaces, titles and names of lobbying targets
recipients of the personal data
are published on the public information network at
avoimuusrekisteri.fi. The email addresses are used
only for sending this communication in accordancewith the GDPR or other significant information to
the lobbying targets, and they are only processed by
the officials of the National Audit Office who needthem to perform their duties.
(f)transfer of personal data
The workplaces, titles and names of lobbying targets
are published on the public information network atavoimuusrekisteri.fi. Information on the email
addresses of lobbying targets is not transferredoutside Finland.
Paragraph 2(a)the period for which the personal
The workplaces, titles and names of lobbying targets
data will be stored
are data that will be stored permanently. They will
be available on the public information network at
avoimuusrekisteri.fi for a period of 10 years startingfrom the submission of the disclosure. After that,they will be archived. Email addresses will be stored
as long as the person continues to be a lobbyingtarget to be named under the Finnish Transparency
Register Act.

NATIONAL AUDIT OFFICE OF FINLANDPORKKALANKATU 1 | PO BOX 1119 | FI-00101 HELSINKI, FINLAND
TEL. +358 (0)9 4321 | WWW.VTV.FI3 (4)(b)(c)–
the existence of the right to requestfrom the controller access topersonal data

the right to request rectification of
personal data

the right to request erasure of
personal data–
The data subject has the right to access the data
recorded on them in the Register. To access thepersonal data recorded in the Register, the data
subject must submit a request to the National Audit
Office’s registry. When making the request, the data
subject must provide proof of their identity.
The data subject has the right to request
rectification of erroneous personal data on them. Inorder to have their personal data rectified, the data
subject must submit a request for rectification to theNational Audit Office's registry. When making therequest, the data subject must provide proof of theiridentity.
The data subject has the right to request erasure of
their personal data if the request for erasure isbased on the following:----

the right to request restriction of theprocessing of personal dataThe data subject can submit a request for erasure of
their personal data stored in the Register to theNational Audit Office's registry. When making therequest, the data subject must provide proof of theiridentity.
The data subject has the right to demand that thecontroller restrict the processing of data if--NATIONAL AUDIT OFFICE OF FINLANDPORKKALANKATU 1 | PO BOX 1119 | FI-00101 HELSINKI, FINLAND
TEL. +358 (0)9 4321 | WWW.VTV.FI

the processing is not necessary in order for thecompetent authority to perform its statutorytask
the data are processed contrary to their
purposethe data that are processed are neither
appropriate nor necessary for the purpose of
their processing
the data that are processed are not accurate
and updated taking into account the purpose of
the processing
specific categories of personal data areprocessed contrary to the conditions for theirprocessing.

the data subject disputes the accuracy of thepersonal data
the processing is contrary to law, and the data
subject objects to the erasure of their personal
data and demands instead that their use berestricted
the controller no longer needs the personal datain question for the purposes of the processing,but the data subject needs them in order toprepare, present or defend a legal claim.

4 (4)(d)(e)–
the right to lodge a complaint with asupervisory authority(f)from which source the personal dataoriginate(g)the existence of automated decisionmaking

To restrict the processing of personal data stored in
the Register, the data subject must submit a request
to the National Audit Office's registry. When making
the request, the data subject must provide proof of
their identity.
–
The data subject has the right to lodge a complaint
with the supervisory authority if the processing of
their personal data infringes applicable dataprotection legislation. The national supervisory
authority in Finland is the Office of the Data
Protection Ombudsman, contact information:
Office of the Data Protection Ombudsman
Visiting address: Lintulahdenkuja 4FI-00530 Helsinki
Postal address: P. O. Box 800
FI-00531 Helsinki
Tel. (switchboard): + 358 (0)29 56 66700
Email: tietosuoja@om.fi
The workplaces, titles and names of lobbying targets
have been collected through requests for
information from the ministries and Parliament and,if necessary, from the public information network.
The email addresses of those working in ministries
are formed automatically from the name and thegov.fi suffix. The National Audit Office receives theemail addresses of those working in Parliament fromthe internal directory.
No profiling or decisions based on automateddecision-making are made on the basis of thepersonal data collected.

DISTRIBUTION Lobbying targets defined in the Finnish Transparency Register Act

NATIONAL AUDIT OFFICE OF FINLANDPORKKALANKATU 1 | PO BOX 1119 | FI-00101 HELSINKI, FINLAND
TEL. +358 (0)9 4321 | WWW.VTV.FI