Valmet Occupational Health Patient Data Register
Privacy policy
This privacy policy concerns the processing of personal data of Valmet Occupational Health’s occupational healthcare clients. In accordance with data protection legislation, this privacy policy provides information on personal data processing activities both to the data subject and to the supervisory authority.
EU General Data Protection Regulation 2016/679 (GDPR)
Data Controller
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Data protection contact personValmet Occupational Health
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Contact informationContact details for data subjects / occupational health clients who wish to obtain more detailed information about the processing of their personal data. See also section 9: Rights of the data subject.
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Data Protection Officers of Valmet Occupational HealthValmet Occupational Health Data Protection Officer:
Deputy Data Protection Officer: Saara Eskelinen, Senior Coordinaator, |
Name of the registerValmet Occupational Health Patient Data Register
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Purpose and legal basis of personal data processingThe processing of personal data is based on the data controller’s statutory obligation to maintain a patient data register. The purposes of processing personal data are:
Act on the Electronic Processing of Client Data in Healthcare and Social Welfare (the Client Data Act, 703/2023) (in Finnish) Folk Pension Act (568/2007) (in Finnish) Act on the Status and Rights of Patients 1992/785 Act on Health Care Professionals 1994/559 Act on the Supervision of Social and Health Care 741/2023 (in Finnish) Health Insurance Act 2004/1224 Workers’ Compensation Act 2015/459 The Archives Act 1994/831 (in Finnish) |
Contents of the registerThe register contains the following information about patients who are currently or have previously been under the care of Valmet Occupational Health: Name, personal identity code, home address, phone number Basic information Employer, work location, business area, department, cost center, work phone number, occupation, personnel number, BC/WC, start and end date of employment Patient record Essential information on the patient’s state of health, visits, provided care, and conducted examinations, documented as a continuous and chronological record Examination records Laboratory, radiology, and other diagnostic examination data Attachments Other documents related to the patient’s care that are not visible in the Kanta services Billing Patient‑related billing information, when required Appointments Date, time, the professional with whom the appointment is booked, booking code, patient’s name and date of birth, and company identifier Other essential care information The patient’s accident and vaccination information, follow‑up needs, and information prepared by other specialists Referrals, statements, and certificates Referrals, statements, certificates, and discharge summaries essential for providing services to the patient Author of entries Name, role, and timestamp of the person who made the entry in the patient record |
Regular sources of informationPatient Information provided by the patient. The accuracy of personal and contact details is verified at each visit. Healthcare personnel Information, reports, statements, and consultation responses generated in connection with examinations and treatment. Documents obtained from other care units with the patient’s consent. Employer Basic information on individuals covered by occupational health services, workplace contact details, and any changes to this information. These details are required to ensure that occupational health services are provided only to those who are entitled to them. Another health care unit or health care professional Based on the occupational health action plan, the number and dates of employees’ sickness absence days. Based on a referral issued by the occupational health unit or under a subcontracted service agreement, information required for verifying billing accuracy, including whom has been treated, what procedures have been performed, and their costs. Insurance companies Information may also be obtained from insurance companies or employment pension institutions.
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Regular disclosures of data (and transfer of data outside the EU or the European economic area)Data may be transferred outside the EU or EEA only within the limits permitted by legislation. In such cases, the transfer is carried out using the European Commission’s standard contractual clauses or another transfer mechanism permitted under data protection legislation. General rule The information contained in patient records is confidential (Section 13 of the Act on the Status and Rights of Patients). Such information may not be disclosed to a third party without the patient’s written consent. A third party refers to anyone other than those participating in the patient’s care or related tasks within the relevant healthcare unit. The obligation of confidentiality remains in force after the end of employment or assignment. Information may be disclosed only on the basis of the data subject’s specific consent. The consent must indicate who is authorised to disclose the data, to whom the data may be disclosed, for what purpose the data is disclosed, and what data is disclosed. The consent must include the date and the patient’s signature. When disclosure requires consent, the patient has the right to withdraw their consent at any time. Disclosure of personal data Personal data may be disclosed to the following parties:
Courts, authorities, or other entities that have a legally mandated right to obtain the information, such as: Personal data may be disclosed to an authority based on a written and specific request, primarily in the form of a statement, to the extent required by the case. The Occupational Safety and Health Division of the Regional State Administrative Agency A doctor is required to report an occupational disease or another work‑related pathological condition (Occupational Safety and Health Act, Section 22, in Finnish). Physicians responsible for communicable disease control in wellbeing services counties A doctor must submit a written notification form regarding any suspected or confirmed generally hazardous or notifiable communicable disease (Communicable Diseases Act 1227/2016, Section 28). The authority responsible for determining the cause of death A doctor or any other person who treated the deceased during their last illness, or who otherwise has relevant information, is obliged upon request to provide the necessary information to the attending physician, the police, or another competent investigating authority for the purpose of determining the cause of death (Act on the Determination of Cause of Death 459/1973, Section 14, in Finnish). Courts and the police A healthcare professional may be compelled to testify about matters covered by confidentiality if the case concerns a criminal offence punishable by six years of imprisonment or more (Code of Judicial Procedure, Section 24). The same conditions apply to testifying during a pre‑trial investigation (Pre‑Trial Investigation Act, Section 27). For the assessment of the validity of a driving licence, firearms licence, or an equivalent permit, the police have the right - on the basis of a justified request - to obtain information relating to the permit holder’s state of health, substance use, or violent behaviour notwithstanding confidentiality, if there is reason to suspect that the person no longer meets the conditions for holding the permit (Police Act, Section 2). Employer A written statement on the conclusions of a statutory health check, insofar as they relate to occupational safety and occupational health care (Occupational Health Care Act 1383/2001, Section 18). Occupational safety authority, and the workplace occupational safety representative For the purposes of verifying the correctness of invoicing, information on who has been treated and, on a separate attachment, what procedures have been performed and the associated costs, may be provided as an attachment to the invoice for occupational health care services. Occupational health doctor of a new employer Right to access the written statement of conclusions of a health check upon request, as stipulated in the Government Decree on Health Examinations in Work Involving a Special Risk of Illness 1485/2001, Section 6. Right to obtain information on a person’s health checks upon request when the person transfers to work that involves a similar level of risk (Occupational Health Care Act 1383/2001, Section 18). Insurance company The doctor responsible for occupational health services at the workplace is obligated to disclose to the insurance institution any information in their possession that is relevant to the processing or decision‑making of an insurance or compensation matter related to an accident at work or an occupational disease (Workers’ Compensation and Occupational Diseases Act 459/2015). Another health care unit or health care professional Information necessary for arranging the patient’s examinations and treatment may be disclosed in accordance with the patient’s verbal consent or consent otherwise evident from the context, which must be recorded in the patient record. The patient’s next of kin or another close person If a patient is unconscious or otherwise unable to express their wishes, information on the patient’s identity and state of health may be provided to the patient’s next of kin or another close person, unless there is reason to believe that the patient would object to such disclosure. Research purposes According to Section 13(4) of the Act on the Status and Rights of Patients, the disclosure of information contained in patient records for scientific research is governed by the provisions of the Act on the Openness of Government Activities, the Act on the Electronic Processing of Client Data in Healthcare and Social Welfare, and the Data Protection Act. For statistical purposes, information may be disclosed to national health registers, such as the adverse drug reaction register (Medicines Act 395/1987, Section 30). |
General principles for protecting patient dataPatient data is classified as confidential. Personal data contained in patient records may not be disclosed to third parties without the patient’s consent or an explicit statutory provision. Patient data may be accessed only by persons involved in the provision of care (Act on the Status and Rights of Patients 785/1992, Section 13 in Finnish). Protection and storage of patient data (described in more detail in Valmet Occupational Health’s Information security plan) The electronic patient information system in use is an A3‑class patient information system approved by the Finnish Supervisory Authority for Welfare and Health (formerly Valvira). The system has undergone an information security assessment and holds a valid information security certificate. The patient data register is not accessible to external parties. Access to the electronic patient information system is possible only through Valmet’s internal network. Use of the system requires strong authentication by a healthcare professional, either by means of a professional ID card with a PIN code or, when using a username and password, through two‑factor authentication. Use of patient data is monitored through regular log data reviews. Patient data outside the electronic patient information system (manual records)
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Rights of the data subjectThe data subject has the right to be informed about the processing of their personal data and to access the data concerning them.
Right to information Every data subject has the right to know what information concerning them has been stored in the register.
Right of access The right of access may be refused only in exceptional cases. Grounds for refusal may include situations where providing the information could cause serious harm to the patient’s health or treatment, or to the rights of another person. If only part of the information must be withheld on these grounds, the data subject has the right to access all other data stored about them. A request for access is made in person during a visit, or by submitting a document that has been signed by hand or otherwise reliably verified. The request may be submitted on a form designed for this purpose (Appendix 1: Request for Access to Patient Records, in Finnish). The request for access is addressed to the Valmet Occupational Health unit. The decision on the right of access is made by the responsible occupational health doctor. The information is provided by the occupational health doctor or occupational health nurse. The data subject’s identity is verified before the information is provided. The data subject is given the opportunity, without undue delay, to inspect the data stored about them in the register. The information must be provided in an understandable form. If the data controller refuses to provide the information, a written certificate of refusal must be issued. The certificate must state the reasons why access was denied. A failure by the controller to provide a written response within three months of the request is regarded as equivalent to a refusal. The data subject may bring the matter before the Data Protection Ombudsman. The Data Protection Ombudsman may order the data controller to grant the right of access. Exercising the right of access is free of charge.
Data subject’s right to rectification The data subject has the right to request the rectification of inaccurate or incomplete data. The controller must, without undue delay, either on its own initiative or at the request of the patient, rectify, delete, or complete any personal data in the patient register that is inaccurate, unnecessary, incomplete, or outdated in relation to the purpose of processing (the purpose of use of the patient register). The data subject has the right to request the erasure of personal data. Requests for erasure are carried out within the limits permitted by legislation. For health data, the controller has a statutory obligation to retain the information in accordance with the Act on the Electronic Processing of Client Data in Healthcare and Social Welfare. A request for rectification must be made in writing to the unit that handled the matter. The request must clearly state the information to be corrected and the replacement information, as well as the date and the signature of the person submitting the request. The request may be submitted using a dedicated form (Appendix 2: Request for Correction of Patient Records, in Finnish). The decision on rectification is made by the responsible occupational health doctor. The rectification is carried out by the occupational health doctor or occupational health nurse. Corrections to patient record entries and/or the deletion of unnecessary information must be performed so that both the original and the corrected entry remain visible in the patient information system. The name, position, date of correction, and the reason for the correction must be recorded in the patient information system. Only the corrected text is visible in the Kanta system. The rectification request is archived as an attachment to the patient record. The patient is notified of the rectification in writing. If rectification is refused, the patient is provided with a written certificate of refusal, which must state the reasons why the request was not accepted. The patient has the right to refer the matter to the Data Protection Ombudsman for review. The Data Protection Ombudsman may order the controller to rectify the data. The data subject has the right to request restriction of processing where they contest the accuracy of their personal data, in which case the processing of the data is restricted for the duration of the verification process.
Data subject’s right to object The data subject has the right to request that the controller not process their personal data for direct marketing, distance selling, other forms of direct advertising, or for market or opinion research. The patient/client/legal representative may withdraw previously given consent at any time, if the processing of personal data is based on consent.
Data subject’s right to data portability The data subject has the right to request data portability, where the data in question has been provided by the data subject themselves and the processing is based on consent or a contract. This right does not apply to patient data. For patient health data, another healthcare provider may view the information in the Kanta Services in accordance with the data subject’s consents and restrictions, which the data subject may manage through the MyKanta service (kanta.fi).
Data subject’s right to lodge a complaint with a supervisory authority The data subject has the right to lodge a complaint with a supervisory authority if they consider that the processing of their personal data infringes data protection legislation. Requests concerning data subject rights must be submitted in writing. Requests must be delivered to the service unit in person, or via a secure online service that requires strong identification, in which case the data subject’s identity is reliably verified at the time the request is submitted. |
Retention and archivingPatient data is retained in accordance with the Act on the Electronic Processing of Client Data in Healthcare and Social Welfare (703/2023) (in Finnish): 12 years after the patient’s death, or - if the date of death is not known - 120 years from the patient’s birth. Unnecessary patient data is destroyed in a manner that prevents access by unauthorised persons. Appointment data created through the Movendos Health Platform (Valmet MyHealth) is archived in the Acute patient information system, where it is retained in accordance with the regulation mentioned above. Messages related to MyHealth remote services are automatically deleted 6 months after the messages have been closed, or they may be deleted immediately after the matter has been resolved, once the necessary entries have been made in the patient record. Electronic pre‑information surveys completed by the patient may be destroyed as soon as their information has been transferred to the electronic patient information system and their purpose of use has been fulfilled. Responses to targeted surveys (mSurvey), for example in connection with health checks or workplace surveys, are retained for a maximum of 3 years from the date of the survey and may be deleted earlier once their purpose of use has been fulfilled. |
Management of the register (described in more detail in Valmet Occupational Health’s Information security plan)In connection with the deployment of the Acute patient information system, the personnel of Valmet Occupational Health received training and instructions on how to use the system. System administrators have received training to support the use of the patient information system. Training and guidance for new personnel of Valmet Occupational Health in the use of the patient information system are provided in accordance with the onboarding. The description of the patient information system’s operating environment, including responsibilities and the division of tasks between Valmet’s internal operations and outsourced services, is defined in the agreements between Valmet and the service provider and their appendices. The personnel of Valmet Occupational Health, including trainees and substitutes, sign a confidentiality agreement as part of their employment contract. These confidentiality agreements are retained as part of Valmet Occupational Health’s administrative documentation. |