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Privacy policy for the subscriber register of Palkeet’s customer bulletins and stakeholder newsletters

Name of the register

Subscriber register of Palkeet’s customer bulletins and stakeholder newsletters


The Finnish Government Shared Services Centre for Finance and HR (Palkeet), Kauppakatu 40, FI-80100 Joensuu, Telephone exchange 02955 62000

Representative of the register controller

Anna Kelho, anna.kelho(at)

Data Protection Coordinator

Sami Nikula, sami.nikula(at)

Purpose of data processing

Managing the personal data intended for sending Palkeet’s customer bulletins and stakeholder newsletter. Processing personal data related to customer bulletins is necessary for implementing an agreement (service agreement) in which the data subject’s employer is a party or for carrying out the relevant pre-agreement measures by request of the data subject.
The customer’s personal data can be processed for the following purposes:

  • service implementation 
  • invitations to client events 
  • management and development of client relationships 
  • development of customer service and business

The personal data related to the stakeholder newsletter is processed based on the consent provided by each data subject upon subscription. Data subjects can withdraw the consent by cancelling the newsletter subscription. This ends the processing of personal data and results in the removal of the data subject’s personal data, as described in ”Due dates planned for the deletion of data groups.”

Description of the groups of data subjects and personal data

In relation to customer communications, the register may contain the following information:

  • contact details, such as name, address, telephone number and e-mail address 
  • title or role

Mailing list for those who have subscribed to the stakeholder newsletter through the Palkeet website ( First and last name, e-mail address, customer agency (if customer), subscriber role (financial administration and/or HR administration).

Groups of recipients of personal data to whom personal data has been or will be disclosed

A separate agreement has been prepared on Palkeet’s role as a controller and Koodiviidakko Oy’s role as a processor of personal data. Koodiviidakko Oy processes personal data on behalf and for the benefit of Palkeet in producing the customer and stakeholder newsletter service.

Data may only be disclosed in accordance with and as permitted by the current legislation. Palkeet or Koodiviidakko may not disclose information in the newsletter subscriber register to other parties for marketing or other purposes. As the controller, Palkeet is responsible for the personal data processing in accordance with the applicable laws and regulations.

Transferring personal data to third countries or international organisations

Information is not transferred outside the EU/EEA or to international organisations.

Due dates planned for the deletion of data groups

The processing of personal data contained by the subscriber register of the customer and stakeholder newsletter begins upon subscription and, for the purposes of managing the customer and stakeholder newsletter, ends immediately once a subscriber cancels the subscription. The personal data of newsletter subscribers are removed from the system at six-month intervals.

Description of the technical and organisational protective measures

Manually processed materials: the materials are not processed in manual format.

Digitally processed materials: Only the employees who are authorised to process the information for their work tasks are permitted to access the system containing customer and stakeholder information. The data in the register is protected against unauthorised viewing, alterations and erasure. The protection measures include user authorisation control, technical protection of databases and servers, physical protection of the facilities, access control, protection of telecommunications, and backup copies of the data. A right to access and process the data is granted if required by a work role. The access to the system is based on personal user identification. The physical location of the data centres and data is in Finland. Administrative controls are used in order to ensure that the operations are carried out appropriately. 

Data sources when the data is not received from the data subject

For the purpose of customer communications, the contact details provided by the customer, the work role, and the services and systems accessible by the customer as per the service agreement are merged. The data subject is the sole data source for the stakeholder newsletter.

The data subject’s right to access the information in accordance with Article 15

A data subject is entitled to the data controller’s confirmation on whether their personal data is processed, and, if the data is processed, to access their personal data. Furthermore, a data subject is entitled to file a complaint to a monitoring authority. The data subject can file a validation request regarding which personal data is processed through LianaMailer at the address

The data in the register will not be used for profiling purposes, and neither will it be subject to automated decision-making.

The right to correct data, in accordance with Article 16

A data subject may request that the data controller rectify, without undue delay, any inaccuracies or errors in the data subject’s personal data. A data subject may update their personal data by cancelling the stakeholder newsletter through the Palkeet website at or by requesting an update through the Extranet service for Palkeet customers (Paletti) or a representative of the data controller.