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PRIVACY POLICY


Data protection safeguards your rights when processing your personal data. Everyone has the right to the protection of their personal data. Data protection is a fundamental right that safeguards the rights and freedoms of data subjects concerning the processing of personal data. The purpose of data protection is to indicate when and under what conditions personal data may be processed. The processing of personal data must always be based on law. An independent authority monitors compliance with the provisions on the protection of personal data. (Source: What is data protection? | Office of the Data Protection Ombudsman)


1. DATA CONTROLLER 

Espoon Englanninkielisen Leikkikoulun kannatusyhdistys ry 

Address: Vanharaide 3A, 02610 Espoo

Business ID: 0982453-2


2. CONTACT PERSON

Contact person: Kindergarten direction Lydia Mccarthy

Contact: 041 5137773 | eel@saunalahti.fi


3. THE PURPOSES AND GROUNDS FOR THE PROCESSING OF PERSONAL DATA

The personal data collected by the kindergarten may be processed for one or more of the following purposes:

  • Provision of early childhood education and pre-school education for children.
  • The application and selection process for pre-school and early childhood education and care places.
  • Management of tasks relating to the relationship with the child, in pre-school education and early childhood education and care.
  • Customer billing.
  • Collecting and analysing statistics relating to early childhood education and care.
  • Recruitment of staff and management of employment relations.

The grounds for processing personal data are:

  • Early Childhood Education Act (540/2018)
  • Data Protection Regulation (2016/679)
  • Data Protection Act (1050/2018)
  • Statistics Act (280/2004)
  • Personal Data Act (523/1999)
  • Basic Education Act (628/1998)
  • Act on Support for Home Care and Private Care of Children (1128/1996)
  • Pupil and Student Welfare Act (1287/2013)
  • Child Protection Act (417/2007)

4. CONTENT OF THE REGISTER

1) Child applying for an early childhood education place:

  • Name, personal identification number, contact details, native language
  • Diseases, allergies and special diets
  • Need for support

2) Guardians of applicants for early childhood education and care:

  • Name and contact details
  • Native language

3) Child attending early childhood education and care:

  • Name, personal identification number, contact details, native language, other languages, information on any security ban
  • Illnesses, allergies and special dietary needs
  • Support measures
  • Daily attendance and absence data
  • Early childhood and/or pre-school education plan
  • Photographs of children, including filming permits
  • Regular updates on activities under the Early Childhood Education and Care Plan and the child's growth, learning and development

4) Children's guardians:

  • Name and contact details
  • Personal identification number
  • Information related to the customer fee and related to the determination of the fee, as well as billing information.

5) Name and contact details of the child's applicant(s), provided separately by the guardians

6) Staff:

  • Name, personal identification number, contact details, native language
  • Education
  • Bank details
  • Pension details
  • Tax information
  • Union information
  • Sick leave information
  • Employment history

7) Chairman of the Board of the Espoo Englanninkielinen Leikkikoulun Support Association:

  • Name and contact details
  • Social security number
  • Information is required by the AVI on the persons controlling the association.
  • Extracts from: the guardianship register, the business insolvency register, the bankruptcy and restructuring register, the enforcement register, and a printout of the roles entered in the Commercial Register.

5. REGULAR SOURCES OF INFORMATION

  • The child and the child's guardians
  • The staff of the kindergarten
  • The information in the register is mainly generated during the customer relationshop, either by the child's guardian or by the kindergarten staff.
  • Data is also collected with consent, for example when visiting a website and sending a completed application form.

6. REGULAR DISCLOSURES OF DATA

As a general rule, the data held by the kindergarten are confidential. Personal data will only be disclosed to the authorities entitled to receive it based on an individual request for information following the legislation on early childhood education and care.

  • The Social Insurance Institution is informed of the data of persons who have started and left kindergarten.
  • Data on children's allergies and dietary restrictions are disclosed to the Food Service.
  • Billing data for kindergartens are transferred to account and collection agencies acting on behalf of the kindergarten for billing, collection and enforcement of client fees. Staff tax, contact and salary data are transferred to the payroll office of the kindergarten. The personal identity number and contact details of staff are passed on to Terveystalo, the company responsible for occupational health care.
  • Personal data on children in early childhood education and care, personal data on carers and staff, and personal data on holders of Varda access rights are transferred to the Varda early childhood education data warehouse.
  • The personal data of the chairman of the board of directors and the data required by the AVI (Regional State Administrative Agency) on the persons controlling the association are transferred to the AVI.
  • Statistical information is provided to the authorities for purposes required by law.
  • Client data of the kindergarten are confidential and the staff are bound by confidentiality obligations. In addition to the specific legislation mentioned above, client data are only disclosed with the explicit and individual consent of the client.  

7. PROTECTIONS

Personal data stored in the register is always treated confidentially and access to it is restricted to essential staff and the Association's Board of Directors. Each employee may only process the personal data that he/she needs for his/her work. Similarly, each member of the Association's Board of Directors may process only the personal data that he or she needs for the performance of his or her duties. Particular attention is paid to the protection of confidential and sensitive data, for example in the case of the transfer of access rights.

The register and its data are stored on a secure server and electronic data transmission is carried out, where necessary, over an encrypted and secure connection.

Manual material, e.g. paper documents, necessary for the organisation and implementation of the client's service are kept in locked and controlled premises.

Data will not be transferred outside the EU or EEA, nor to international organisations.

Personal data will be destroyed when the reason for their retention and use ceases to exist.


8. INFORMING THE DATA SUBJECT

The privacy notice is available at the Espoon Englanninkielinen Leikkikoulu offices. 


9. RIGHT OF ACCESS AND EXERCISE OF THE RIGHT OF ACCESS

A person may submit a request for inspection in person or in writing. For minors, the right of inspection is exercised by their guardian or another legal representative.

The request is addressed to the director of the kindergarten. The identity of the data subject will be verified and, if necessary, checked before the data are disclosed.

Every effort will be made to make the information available without delay. If the data subject is refused access, he or she will be given written confirmation of the refusal. The certificate shall state the reasons for the refusal. The data subject then has the right to refer the matter to the Data Protection Officer. (https://www.tietosuoja.fi)


10. RECTIFICATION AND IMPLEMENTATION OF RECTIFICATION

If the data subject becomes aware that inaccurate or incorrect personal data concerning him or her have been recorded, he or she has the right to request the controller to correct them. Rectification means that the inaccurate data will be corrected, deleted and incomplete data may be completed.

The data will be corrected without undue delay. The request for rectification shall be made in writing and sent to the director of the kindergarten. The identity of the data subject will be verified and, if necessary, checked before the data are provided.

The Data Controller must reply to the data subject within one month. In case of multiple or complex requests, the controller may indicate in its reply that it needs more time to process them. In this case, the deadline is three months after the initial request.

In the event of a refusal to rectify the information, the data subject will be given written confirmation of the refusal. The certificate shall state the reasons why the request has not been accepted. The data subject then has the right to refer the matter to the European Data Protection Supervisor (EDPS). (https://www.tietosuoja.fi)


11. RIGHTS OF THE DATA SUBJECT

All natural persons whose data have been stored by Espoo Englanninkielinen Leikkikoulu in such a way that they have become part of the personal data file have the following rights:

  • The right to check the data concerning themselves.
  • The right to have his/her data rectified in the event of an error.
  • The right to request the deletion or transfer of their data from one system to another.
  • The right to restrict or object to the processing of your data. 
  • The right to withdraw your consent to the processing of your data.
  • The right to complain to a supervisory authority.
  • The right to object to the use of your data for direct marketing purposes.

We would love to see your child in our kindergarten!