Privacy Policy

Privacy Policy, issue date 14:th December 2023 EU General Data Protection Regulation (2016/679)

1. Controller

The Centre for Economic Development, Transport and the Environment of Southwest Finland

Contact details

Centre for Economic Development, Transport and the Environment of Southwest Finland
Itsenäisyydenaukio 2
P.O. Box 636
20801 Turku, Finland

tel.+358 295 022 500
[email protected]

2. Contact person for matters concerning the register

Markus Kivelä, Project Manager for Public Transport
Centre for Economic Development, Transport and the Environment of Southwest Finland
Itsenäisyydenaukio 2
P.O. Box 636
20801 Turku, Finland

The joint Data Protection Officer of the ELY Centres is Sanni Harju, deputy colleague Mia Niskanen.

3. Register name

Ticket system customer register of the Centre for Economic Development, Transport and the Environment of Southwest Finland
Ticket system online service customer register of the Centre for Economic Development, Transport and the Environment of Southwest Finland

3. Purpose of and justification for the processing of personal data

Travel card system customer register:

The data is used to manage the customer relationship between the public transport unit of the Centre for Economic Development, Transport and the Environment of Southwest Finland and the customer, as well as to implement the service. The customer’s identification data is used to check their right to purchase a personal travel card and to verify the validity of the customer’s personal transactions.

  • in the provision of a personal travel card, where the customer’s right to purchase is verified and established.
    • personal identification number is used to check the right to purchase a school transport subsidy ticket from KELA (Social Insurance Institution of Finland).
  • in the closure of a lost travel card ID
  • in exchanges related to a damaged travel card ID
  • in identifying the owner of a found travel card ID
  • in the identification of a customer in cases involving the refund of tickets linked to a travel card ID and in connection with error settlements
  • in the verification of a customer’s ticket product loading events and possible demonstration events
  • in the provision of personal ticket product travel rights data into the online service application on the basis of the customer’s search query. The retrieval of card information requires the customer to strongly verify their identity using their online banking ID.
  • in closing a travel card account at the end of a customer relationship
  • in the identification of the customer at the end of their customer relationship.

Customer register for the online service and mobile service:

The data is used for the production and implementation of the service (products to be loaded onto a travel card ID or mobile ticket ID) and for customer-related communication purposes. The customer’s identification data is used to verify the validity of the customer’s personal transactions.

The basis for the use of the personal identity code is the reliable and individualised identification of the customer in the register in order to ensure the implementation of the rights and obligations of the customer, data controller and public transport authorities.
in the verification of a customer’s ticket identifier loading events and possible demonstration events

  • in the provision of personal ID data into the online service application on the basis of the customer’s search query.
    • Checking the right to right to purchase a school transport subsidy ticket from KELA (Social Insurance Institution of Finland).
  • The retrieval of card or ID data requires the customer to verify their identity.
  • in the identification of the customer at the end of their customer relationship.

The processing of personal data is primarily based on the implementation of the agreement and the legitimate interests of the Centre for Economic Development, Transport and the Environment of Southwest Finland, the data controller or a third party and the implementation of said interests. The processing may be necessary for ensuring the data controller’s statutory compliance and/or for exercising the public authority vested in the data controller.

The data can also be used for the planning, development and statistical needs related to the data controller’s own activities.

5. Data content of the register

Travel card system customer register:

Contains the following data on the public transport customers of the Centre for Economic Development, Transport and the Environment of Southwest Finland: (This data includes travel data with location data.)

Customer data

  • start and end date of customer relationship
  • customer identifiers: name, municipality of residence and domicile, address, language
  • possible phone numbers and email address

Basic travel card ID data

  • travel card ID number
  • travel card ID registration date
  • the travel card ID end date and reason code for the closure of the travel card

ID event history

  • fulfilment and cash transaction data
  • travel card provision date and time
  • seasonal ticket product deployment data (ticket validity data)
  • transaction data for serialised and billable ticket products
  • last use event (date, time, ticket product and line on which the card was used)
  • possible usage attempts (unsuccessful card reader stamping event, reason code)
  • ID status information (closed, opened, found, defective, replaced, etc.)

Customer register for the online service and mobile service:

Contains the following data on customers (including travel data with location data):

Customer data

  • start and end date of customer relationship
  • customer identifiers: name, municipality of residence and domicile, address, language. Strong identification may also require other personal data, but this data is not stored in the ticket system’s registers.
  • possible phone numbers and email address

Basic ID data

  • travel card/ID number
  • customer’s travel card/ID-specific user group (purchase rights) and its possible fixed-term period of validity

Event history of the travel card/ID

  • fulfilment and cash transaction data
  • top-ups made to travel card/ID
  • seasonal ticket product deployment data (ticket validity data)
  • last use event (date, time, ticket product and line on which the card was used)
  • ID status information (closed, opened, found, defective, replaced, etc.)

6. Regular data sources

The customer data in the customer registers is obtained from the customer with their consent, the guardian of a minor, a person authorised by the customer, or from the Population Information System of the Digital and Population Data Services Agency. The personal data can be updated from the aforementioned systems.

7. Regular disclosure of data and categories of recipients

The data can be disclosed to the data controller, authorities and system service providers for the purposes described in section 4 of this Privacy Policy.

8. Transfer of data outside the European Economic Area

No data is transferred outside the EEA.

9. Register protection principles and storage period of personal data

Travel card system customer register:

A data protection agreement has been concluded between the data controller and the system vendors. The system vendors manage the customer register and the storage of the data contained in it in accordance with good data processing practices and comply with their absolute obligation to secrecy and confidentiality.

At the end of the customer relationship, the customer data will be deleted immediately unless other legal obligations prevent the deletion of said data. Once the data has been deleted, no complaints, rebates or error resolution measures can be enacted.

Customer register for the online service and mobile service:

A data protection agreement has been concluded between the data controller, the authorities, the owners of the products sold in the store, and system vendors. The system vendors manage the customer register and the storage of the data contained in it in accordance with good data processing practices and comply with their absolute obligation to secrecy and confidentiality.

At the end of the customer relationship, the customer data will be deleted immediately unless other legal obligations prevent the deletion of said data. Once the data has been deleted, no complaints, rebates or error resolution measures can be enacted.

Access rights and their management

The access rights to customer registers for the personnel of the public transport unit and its customer service points as part of their duties is determined by the main administrator of the Centre for Economic Development, Transport and the Environment of Southwest Finland and the responsible persons authorised by said main administrator.

Any access rights that are based on individual contractual relationships for persons processing customer register data (for example, at other possible service points) are defined according to the principles stated in the commission agreement between the Contractor and the Centre for Economic Development, Transport and the Environment of Southwest Finland.

The processors must comply with the absolute obligation to secrecy and confidentiality. This access right is terminated when the person steps away from the tasks to which they have been granted access.

The obligation to secrecy and confidentiality continues even after the end of the duties or employment relationship that included the processing of customer data.

Access control

The access control register is used to monitor the work duty-related use of the register as well as all attempts to use it. The data required for monitoring is stored in both a database and log file. The subsystems of each service log their activities in accordance with their control parameters. The log files are stored in a file system which can be accessed (read or write access) only by those persons responsible for maintaining the service.

As a rule, the log files are stored for nine (9) months.

Data on the use of the registers is stored in the database for access monitoring purposes (user name, timestamp, search criteria and reason). The data stored in the database can be used to monitor and report on the proper use of the customer registers. This data is used to produce the reports necessary for usage monitoring purposes. The log file is used to store all searches and changes made to customer data on a per-user and date basis, as well as the identifier data of the user who submitted the query.

Technical maintenance

The system vendors are responsible for maintaining the technical integrity of the customer register. Technical data related to the system is needed to maintain and ensure the technical usability and integrity of the system. Events generated by the device are recorded as technical data. Personal data is not collected or stored as technical data.

Ensuring usability

All data is protected against intentional and unintentional destruction (e.g. central devices are stored in access-controlled and locked facilities, and files are backed up in a separate fire-secure department), and the integrity of the data is protected by managing its security through technical maintenance data and event data. The internal data connections of the system have been implemented through closed networks. All external connections are secured with firewalls. The system and its data connections are monitored 24 hours a day.

10. Other rights of the data subject in relation to the processing of personal data

The data subject’s right of access

When a data subject signs in to the online service or mobile service, they will always have access to most of the data that pertains to them in the service.
The data subject also has the right to check what is stored about them in the system’s customer register. Any access right requests must be made in accordance with section 11 of this Privacy Policy. In principle, this right of access is free of charge.

If the requests submitted by the data subject are manifestly unfounded or unreasonable, in particular in cases where they are submitted repeatedly, the data controller may either charge a reasonable fee, taking into account the administrative costs of submitting the data or messages or carrying out the requested action, or refuse to carry out the requested action. In such cases, the data controller must demonstrate the manifestly unfounded or unreasonable nature of the request.

The right of the data subject to demand the rectification or erasure of data or limit the processing of data

The data subject can update their basic data in both the system’s customer register and the customer register of the online service and mobile service. To the extent that the data subject is permitted to act on their own behalf, they must, without undue delay, after having been informed of or personally discovering an error, rectify, delete or supplement the incorrect, unnecessary, incomplete or obsolete data contained in the registers.
To the extent that the data subject is unable to correct the data on their own behalf, the request for correction must be made in accordance with section 11 of this Privacy Policy.

The right of the data subject to object to the processing of personal data

In relation to any personal special situations, the data subject has the right to object to the profiling and other processing activities that the Centre for Economic Development, Transport and the Environment of Southwest Finland subjects the personal data of the data subject to. This objection is limited the extent that the processing of the data is based on the customer relationship between the Centre for Economic Development, Transport and the Environment of Southwest Finland and the data subject. The data subject may submit their objection in accordance with section 11 of this Privacy Policy. In connection with their objection, the data subject must identify the special situation on the basis of which they object to the processing. The Centre for Economic Development, Transport and the Environment of Southwest Finland may refuse to implement the objection request on the grounds laid down by law.

The right of the data subject to transfer data from one system to another

If the data subject has personally submitted data to the customer register of the travel card system and to the customer register of the online service and the mobile service and the data is processed on the basis of the consent given by the data subject, the data subject has the right to receive such data in a predominantly machine-readable format and to transfer this data to another data controller.

The right of the data subject to file a complaint with the supervisory authority

The data subject has the right to file a complaint with the competent supervisory authority if the data controller has failed to comply with the applicable data protection regulation.

Other rights

If personal data is processed on the basis of the data subject’s consent, the data subject has the right to withdraw their consent by notifying the Centre for Economic Development, Transport and the Environment of Southwest Finland in accordance with section 11 of this Privacy Policy.

11. Contacts

In all questions related to the processing of personal data and in situations related to the use of personal rights, the data subject must contact the service point, the Centre for Economic Development, Transport and the Environment of Southwest Finland by email at: [email protected]
or by mail at:

Centre for Economic Development, Transport and the Environment of Southwest Finland
Public transport matters
P.O. Box 636
20101 Turku, Finland

If necessary, the Centre for Economic Development, Transport and the Environment of Southwest Finland may request the applicant to verify their identity. The data controller will respond to the customer within the time limits laid down in the EU’s General Data Protection Regulation (as a rule within one month).