PRIVACY STATEMENT
1 (3)Article 12 of the General Data Protection Regulation (679/2016)
Date of issue
Updated

1 Name of register

Finnish Transparency Register

2
Data controller

National Audit Office of Finland (NAOF)

31 October 2023
11 July 2024

Porkkalankatu 1
FI-00101 Helsinki+358 (0)9 4321
kirjaamo@vtv.fi
3
Contact personforregister-relatedmatters
4
Data ProtectionOfficer

5
Purpose of
personal dataprocessing

6
Data containedin the register

Jonna Carlson
National Audit Office of Finland (NAOF)
Porkkalankatu 1
FI-00101 Helsinki+358 (0)9 4325897
jonna.carlson(at)vtv.fi
Data Protection OfficerMari Tölli
National Audit Office of Finland (NAOF)
Porkkalankatu 1
FI-00101 Helsinkitel. +358 (0)9 4325863
tietosuojavastaava@vtv.fi
The National Audit Office's right to process personal data is based on the Transparency Register Act(23.3.2023/430). The data is processed in the manner laid down by the data protection legislation. No
profiling or decisions based on automated decision-making are made on the basis of the personal datacollected.
Only the personal data laid down in the Transparency Register Act is stored in the register.
The data entered in the Finnish Transparency Register includes the registrations, disclosures ofactivities, changes to the registration and changes to the activities submitted by a legal person or a
private entrepreneur engaged in lobbying or lobbying consultancy (actor subject to the disclosureobligation), as well as the parties to a penalty payment procedure or request for clarification.
The content of a registration is provided for in section 6 of the Transparency Register Act, the contentof a disclosure of activities in section 8 of the Act, and the content of a change notification in section 7of the Act. The penalty payment procedure is provided for in section 9(3) of the Act, and requests forclarification are provided for in section 10 of the Act.
The data referred to in section 6 and disclosed to the Finnish Transparency Register is published on
the public information network.
The personal data concerning parties subject to the disclosure obligation stored in the Finnish
Transparency Register consist of the name and personal identity code of the person submitting thedisclosure. On a voluntary basis, an e-mail address to which system messages can be sent and atelephone number can be provided for the register. The personal data are collected for the purposesof the registrar’s oversight and maintenance activities, and they are not published in a public
information network. The personal identity codes are protected separately.
For customers of lobbying consultancy, e-mail addresses and/or telephone numbers are collected ascontact information. The information is collected for the purposes of the registrar’s oversight andmaintenance activities, and it is not published in a public information network.

NATIONAL AUDIT OFFICE OF FINLANDPORKKALANKATU 1 | PO BOX 1119 | FI-00101 HELSINKI, FINLAND
TEL. +358 (0)9 4321 | WWW.VTV.FI2 (3)For lobbying targets, their workplaces, job titles and names are stored in the Finnish Transparency
Register, as well as their e-mail addresses as contact information. The workplaces, job titles andnames are published in a public information network at avoimuusrekisteri.fi. The e-mail addresses areonly used to inform the lobbying targets, and they are not published on a public information network.
7
Regulardata sources
8
Datarecipients
9
Transfer of dataoutside the EUor the EEA
10Register
protection
principles

Legal persons and private entrepreneurs referred to in section 3 of the Transparency Register Act thatare engaged in lobbying or lobbying consultancy and that are subject to the disclosure obligation.
Access to non-public data entered in the Finnish Transparency Register is restricted only to theofficials of the National Audit Office who need it for performing their tasks and, where appropriate, toexperts designated by the National Audit Office. If necessary, the system vendor Ambientia Oy isgranted separately access to the data.
Personal data is not transferred outside the EU/EEA area.

The register is handled with due care, and the data processed by means of information systems isprotected appropriately. The controller ensures that the stored data is processed confidentially.
Access to the data processed in the information system is restricted to persons specifically designatedand authorised by the controller. It is checked regularly that the access rights are up to date.
The information network and the terminal equipment where the register is located are protected bytechnical measures.

11Right to access,rectify, erase andrestrict theprocessing of dataand to withdraw
consent

The rectification of personal data is provided for in Regulation (EU) 2016/679 of the European
Parliament and of the Council on the protection of natural persons with regard to the processing ofpersonal data and on the free movement of such data, and repealing Directive 95/46/EC (GeneralData Protection Regulation). In addition, provisions on the correctness of public authorities' data arealso laid down in the Act on Information Management Governance in Public Administration(906/2019).
The General Data Protection Regulation (2016/679) and the Data Protection Act (5.12.2018/1050)
apply to the right of a person to erase or restrict the processing of their personal data and towithdraw their consent.

12The right to lodge
a complaint with asupervisory
authority

The data subject can submit a request related to personal data in the register to the National Audit
Office's Registry. When making the request, the data subject must provide proof of their identity.
A data subject has the right to lodge a complaint with the supervisory authority if the processing of
their personal data violates applicable data protection 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

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

3 (3)
13
Other information

Personal data is not used or disclosed for direct advertising, distance selling or other direct marketingor for market research and opinion polling or for public registers or genealogical research.
Any detected risks or problems related to data protection can be reported to the National Audit Officeby email: kirjaamo@vtv.fi

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