DATA PROTECTION AND PRIVACY STATEMENT FOR PRO ARTE
FOUNDATION FINLAND’S PARTNERS IN COLLABORATION AND JOURNALISTS
1. REGISTER KEEPER
Pro Arte Foundation Finland [“The Foundation”]
Business Identity Code: 21485721
2. CONTACT INFORMATION IN MATTERS RELATED TO THE REGISTER
Pro Arte Foundation Finland
address: Kalevankatu 4, 2nd floor 00100 Helsinki
3. NAME OF REGISTER
Pro Arte Foundation Finland’s register of partners in collaboration and journalists
4. DATA CONTENT OF REGISTER
Pro Arte Foundation Finland’s (IHME) register of partners in collaboration and journalists can be used to
store information on partners in collaboration or journalists including the following:
a. data on partner in collaboration or journalist (Business Identity Code, address, e-mail
address, phone number)
b. details of contact person for partner in collaboration or journalist (name, address, phone
number, e-mail address, registered position at organization)
c. billing information for partner in collaboration or journalist
d. details of services ordered
5. PURPOSE OF AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
Personal data are stored to maintain the relationship between The Foundation and its partners in
collaboration and journalists, and to perform tasks and duties related to orders and events. Personal
data are also processed as part of the planning and development of The Foundation’s own operations.
Personal data are further stored to fulfil the register keeper’s statutory responsibilities.
The legal basis for the processing is the collaborative (agreement) or media relationship between The
Foundation and its partner in collaboration or journalist, or the register keeper’s legitimate interest in
that relationship. Personal data can also be processed in order to fulfil the register keeper’s statutory
6. PERSONAL DATA RETENTION PERIOD
Personal data of partners in collaboration and journalists are as a rule stored for as long as the
collaborative or media relationship is in effect. Once the collaborative relationship has ended personal
data can be stored for as long as the parties to the agreement have the possibility of making legal
claims on each other or for as long as the register keeper’s statutory duty requires it. Journalists can at
any time unsubscribe from the mailing list intended for journalists.
7. THE REGISTER’S REGULAR SOURCES OF DATA
Personal data are acquired directly from the registered individual or organization (data subject) when
they make the collaboration agreement or when the journalist personally subscribes to the list for the
purpose of their work or when The Foundation (IHME) adds them to the list, or later on when the
collaborative or provider relationship is an ongoing one. Personal data can also be collected and
updated from publicly available sources of information, such as the Finnish Trade Register or company
8. REGULAR DISCLOSURE OF INFORMATION
Personal data will not be disclosed as a rule to anyone outside The Foundation or its partners in
collaboration or other service providers acting on its behalf. The Foundation only uses high-quality
third-party service providers to assist it in its processing of personal data, and with whom it has made a
GDPR-compliant agreement on the processing of personal data.
9. DISCLOSURE OF INFORMATION OUTSIDE OF THE EU OR ETA
Personal data will not be not transmitted or disclosed outside the EU or ETA.
Gruppo Software may process personal data outside of the EU. Gruppo Software undertakes to use
methods that comply with the EU’s General Data Protection Regulation (GDPR).
10. REGISTER’S PROTECTION PRINCIPLES
The Foundation protects the personal data contained in the register with appropriate technical and
organizational measures which are used to ensure that the processing of personal data complies with
the data protection regulations.
Unauthorized bodies do not have access to register data. Only the register keeper and people
individually designated by the register keeper can gain access to the personal data contained in the
register. Only individually designated individuals have the right to process and maintain the personal
data contained in the register. Everyone who is given the right to access the data also undertakes to
comply with the duty of confidentiality.
The information systems and computer equipment maintained using information technology in which
the register is located are protected by the customary technical safeguards, such as firewalls and userspecific passwords. The computer equipment is kept in locked premises.
Manual material is stored in a separate archive in locked premises that can only be accessed by workers
with the right to process personal data.
11. REGISTERED DATA SUBJECT’S RIGHTS
Pro Arte Foundation Finland undertakes to implement, either on its own initiative or at the request of
the data subject listed in the register and without undue delay, the data subject’s rights as described
below. If a request for information affecting the registered person’s rights is not approved, the data
subject will be given a reasoned notification stating why the request has not been approved.
11.1. RIGHT OF INSPECTION
The data subject has the right to know what data concerning them is stored in the
personal register or that the register does not contain data concerning them.
The data subject should submit an inspection request in a document containing their
handwritten signature or verified by some other corresponding method. The request is to
be addressed to the register’s contact information address. Inspection requests are free of
charge when made at most once a year (12 months).
11.2. RIGHT TO REQUIRE RECTIFICATION OF DATA
If the data subject notices that there is inaccurate or erroneous personal data in the
register, the data subject has the right to require such data to be rectified.
Data rectification requests should be made in writing and include enough individual detail
to allow implementation of the request: at a minimum the request should give the data
subject’s name, details of the inaccurate or erroneous personal data and the completed or
corrected data. The request should be submitted in a document with a handwritten
signature or verified by some other corresponding method. The request is to be
addressed to the register’s contact information address.
11.3. RIGHT TO REQUIRE RESTRICTION OF PROCESSING OR ERASURE OF DATA
The data subject’s right to require restriction of processing or erasure of data only applies
in certain circumstances.
The data subject has a right to require restriction of the processing of their personal data,
for example, in a situation in which the data subject is waiting for the register keeper’s
answer to a request to restrict or delete their data.
The data subject has a right to require the register keeper to erase their personal
information, for example, if 1) the personal data are no longer needed for the purpose for
which they were collected or for which they were processed or 2) the data subject
withdraws their consent on which the processing is based and there is no other legal basis
for processing their personal data.
Requests to restrict processing of or to erase data are to be addressed to the register’s
11.4. RIGHT TO WITHDRAW CONSENT
When personal data are processed on the basis of the data subject’s consent (for
example, for direct marketing), the data subject has the right to withdraw their consent.
Withdrawal of consent has to be made as easy as giving consent. Requests to withdraw
consent are to be addressed to the register’s contact person.
11.5. RIGHT TO OBJECT TO PROCESSING OF DATA
The data subject has the right to object to the processing of their personal data if the data
subject, for example, considers that the register keeper has processed their personal data
illegally or that the register keeper has no right to process some of their personal data.
11.6. RIGHT TO COMPLAIN TO THE DATA PROTECTION OMBUDSMAN
The data subject has the right to complain to the Data Protection Ombudsman if they
think the register keeper has not adhered to the relevant data protection regulations.
12. CHANGES TO THE DATA PROTECTION AND PRIVACY STATEMENT
Pro Arte Foundation Finland reserves the right to make changes to this data protection and privacy
statement in order to comply with its legal responsibilities. Changes can be necessary, for example,
because of a change in the relevant laws or of changes in The Foundation’s operations.