Privacy statement of Ilmarinen's customer register

According to the European Union’s General Data Protection Regulation (GDPR) 679/2016, articles 12–14.

1. Name of personal data register

Ilmarinen’s customer register

2. Controller

Ilmarinen Mutual Pension Insurance Company
Porkkalankatu 1
00018 Ilmarinen
Helsinki

Contact person for matters related to the register:
Data Protection Officer
Anttipekka Murhu
tietosuoja@ilmarinen.fi
Tel. +358 10 284 2249

3. Forwarding of data subject’s requests

Written requests concerning the rights of the data subject, in accordance with sections 11–16, shall be addressed to:

Henkilötietoasiat
Ilmarinen Mutual Pension Insurance Company
Porkkalankatu 1, FI-00018 ILMARINEN

4. Grounds for processing of personal data

Ilmarinen’s task pursuant to the Act on Employment Pension Insurance Companies is to practice statutory pension insurance which is part of social security by taking care of the implementation of statutory pension security and the assets accruing with the company for this purpose in a manner that secures the benefits covered by the insurance. In connection with these tasks, the processing of personal data is based on statutory requirements. In relation to the execution of this statutory task Ilmarinen can also offer its customers other services based on consent and contract. Data subjects have the right to withdraw their consent.

The secondary grounds for the processing of personal data is legitimate interest.

The basis for the marketing targeted at Ilmarinen’s customers is legitimate interest or consent and for the marketing targeted at other interest parties’ legitimate interest.

5. Purposes

The personal data in Ilmarinen’s customer register is processed for the following purposes:

Provision of services

Offering and production of services provided by Ilmarinen and its cooperation partners, such as

Tasks related to earnings-related pension insurance and
managing the insurance portfolio
Taking care of pension and rehabilitation services, such as
processing applications, decision-making and payments
Offering additional services and customising services

Customer identification, managing user rights, securing and
substantiating service transactions and resolving error situations
Managing finances and money transactions and accounting, incl.
payments, invoicing, ledgers and debt collection

Developing services and operations

Planning and developing services, operations and IT systems
Steering of services and operations and quality assurance

Customer account management and customer service

Managing and developing customer and stakeholder relationships
Customer guidance and the implementation and development of customer
services
Co-operation and marketing of Ilmarinen’s economic interest grouping
Monitoring and development of the customer experience

Ilmarinen records calls in order to substantiate service transactions, develop customer services, fulfil rights and obligations and ensure security.

Analysis of customer relationships and operations

Analysis, statistics creation and reporting of Ilmarinen’s operations and
services
Analysis, grouping and reporting of customer relationships and service
offering
Development and management of total customer relationships and service concepts

Customer relationship and marketing communications

Targeting of customer communications and marketing
Implementation and monitoring of communications and campaigns

Information security

Ensuring the availability, integrity and reliability of services and
information
Prevention, detection and resolving of misconduct and problem situations and starting up and implementation of follow-up measures
Risk management

6. Categories of personal data

The following personal data are recorded in Ilmarinen’s customer register:

Data related to persons in the policyholders’ pension and insurance services

Data required for identifying and contacting policyholders’ (TyEL and
YEL) representatives and companies’ owners, such as

Name and position in company
Contact details
Identity number
Identifiers in information systems

Personal data processed in connection with insurance and appeal
application processing, decision-making, agreements and insurance
transfers
Personal data related to offering services and insurance and
service transaction and usage data
Personal data required for managing the customer relationship and insurance portfolio
Calculations concerning insurance and need for insurance
Data on links to other customers
Insured persons and pension recipients linked to policyholder

Personal data linked to insured person’s customer account

Insured person’s basic information and contact details, such as

Name, address, telephone, email
Identity number
Identifiers in information systems

Insured’s contact persons and trustees and their identification
information and contact details
Personal data related to offering services and insurance and
service transaction and usage data
Work history and pension accrual data and advance
calculation and earnings-related pension record data
Personal data required and collected for the management of the customer relationship and customer service and telephone recordings
Personal data required and collected in connection with customer
relationship and marketing communications and campaigns
Consent and refusal and customer communication subscriptions
Grouping and classification data describing a customer account and
additional identifying data given by the customer
Data linked to the processing of appeal and rectification matters

Data concerning pension and rehabilitation customers’ customer accounts

Basic information and contact details of pension and rehabilitation benefit applicants and persons who have received decisions and their contact persons and trustees, such as

Name, address, telephone, email, nationality and mother tongue
Identity number
Identifiers in information systems
Pension recipient’s account number
Employment information

Data required for offering pension and rehabilitation services,
managing, controlling and monitoring pension security, such as

Data linked to pension and rehabilitation applications,
resolution and decision and requests for rectification
Personal data required and collected for the management of the customer relationship and customer service and telephone recordings
Data on pension amount, payments, payment recipients and
taxation
Benefit history and medical data
Data linked to the management and transfers of the pension portfolio

General personal data related to service production

Data subject’s basic information and contact details, such as

Name, address, telephone, email
Identity number
Identifiers in information systems

Personal data related to offering services and service transaction and
usage data
Personal data required and collected for the management of the customer relationship and customer service and telephone recordings
Data recorded in connection with customer advice and contacts and
customer feedback
Personal data required and collected in connection with customer
relationship and marketing communications and campaigns
Consent and refusal given by the customer and customer communication subscriptions
Grouping and classification data describing a customer account and
additional identifying data given by the customer
Data collected for research and statistics
Accounting, payment, invoicing and debt collection data

Data required and created in electronic service production

Data required by the online service for identification and user rights,
such as

User ID and password
Other identifiers identifying the online service user

Web and mobile services usage data, such as

Browsing, log and service transaction data and data on the
website from which Ilmarinen’s service has been accessed

Online identifiers and data on the used channel, application, device
and browser, such as

The device’s model
Data on the used application
Data on the used browser and operating system
Online identifiers, such as cookies and IP addresses, calculated
identifier
Session identifiers: time and duration

Location data (GPS, WLAN or location data formed using a mobile
network base station) based on the customer’s consent
Data linked to the processing of data in the information systems

7. Use of cookies

The cookies used in Ilmarinen’s online service and any other internet identifiers enable the implementation of the online service and improve the security and user-friendliness of the services.

Based on the data collected in the online service, Ilmarinen can analyse and develop its services, knowing what information contents interest users and how the online service is used. The data can also be used for Ilmarinen’s and its marketing partners’ communications, targeting of marketing and for optimising marketing measures.

The online service user can give his/her consent or refuse the use of cookies in his/her browser settings or use a service designed for the purpose. If cookies are disabled, some of the services on Ilmarinen’s website may not be available.

8. Regular data sources

Ilmarinen receives personal data from the data subject during the use of the service. Ilmarinen also receives data on the insured persons and pension recipients from other pension companies and employers, for example. Personal data is also collected in connection with service transactions and the use of services.

Ilmarinen also regularly receives personal data from e.g., the following data sources:

Finnish Centre for Pensions
Social Security Institution
Earnings data forwarding services
Doctors, hospitals and health centres
Labour authorities
Tax authorities
Social welfare authorities
Unemployment funds and employment offices
Enforcement officers
Insurance companies
Banks
OP Financial Group
Accountants
Suomen Asiakastieto Oy
Population Register Centre
Pension Appeal Board
Insurance Court

9. Disclosures and transfers

Ilmarinen only discloses personal data in accordance with the right to be informed based on legislation and in accordance with disclosure rights and obligations. In special cases, personal data can be disclosed also with the consent of the data subject. The disclosure parties and grounds are described in the guidelines of the Finnish Centre for Pensions.

Personal data can be transferred to Ilmarinen’s service providers acting on behalf of Ilmarinen. The processing of the personal data of people operating on behalf of Ilmarinen is always based on order contracts and instructions, which specify the parties’ rights and obligations in the processing and protection of personal data.

Ilmarinen primarily processes personal data in Finland, the EU/EEA area or in other countries approved by the EU Commission as having a sufficient level of data protection. To ensure a sufficient level of data protection, the standard contractual clauses approved by the European Commission are used. When personal data is transferred to the United States, the transfers may also be based on the EU-U.S. Data Privacy Framework.

Personal data is transferred from Ilmarinen’s customer register to Ilmarinen’s marketing register for marketing purposes. The privacy statement of Ilmarinen’s marketing register contains more details on the marketing register’s information content and the processing of personal data.

10. Automatic decision-making

Ilmarinen speeds up and improves its services to customers by using automatic decision-making when assessing whether statutory terms are met in the processing of insurance and pensions matters. If the statutory terms are not met, the processing is moved to the manual process.

The customer has the right to appeal decisions made by Ilmarinen that apply to him/her. Information on appeals is given in connection with the decision.

11. Right of access

A data subject is entitled to access the data that has been recorded in the register on him/her.

The data subject must present in the request for access his/her name and personal identity code so that the data can be found. The response to the request for access will be delivered to the data subject’s verified address.

12. Right to data portability

The processing of personal data at Ilmarinen is primarily based on carrying out its statutory obligation, in which case there is no right to data portability. This applies to the processing of personal data linked to the implementation of earnings-related pension coverage and the management of investment operations, as well as to Ilmarinen’s activities as an employer and company, even if the processing is defined through agreements when necessary.

Otherwise, the data subject is entitled to receive as a file the personal data processed by the information systems that applies to him/her, which he/she has supplied to the controller and whose processing is based on the data subject’s consent or a contract with the data subject. The data subject may also request that the controller transfer the data in question to another controller, if this is technically possible.

13. Right to rectification

The data subject is entitled to require that inaccurate personal data be rectified. The changes in personal data will primarily be made in connection with use of the service following authentication.

The request must contain the name and identity number, specific and justified request for rectification and an explanation of how the information should be rectified.

14. Right to object

In terms of the processing of personal data based on Ilmarinen’s statutory obligation, the data subject is not entitled to object to the processing of personal data.

The data subject is entitled to object to the processing of personal data that applies to him/her when the processing is based on legitimate interest, such as direct marketing. Instructions for objecting to marketing can be found in the privacy statement for Ilmarinen’s marketing register.

15. Right to restriction of processing

The data subject can request that Ilmarinen restrict the processing of his/her personal data when:

The accuracy of the personal data is contested by the data subject.
However, there is no right of restriction on the part of Ilmarinen’s statutory operations if the request for restriction is manifestly unfounded.
The processing is verifiably and justifiably unlawful and the data
subject opposes the erasure of the personal data.
When Ilmarinen expresses that it no longer requires the personal data
that has been requested to be restricted for the purposes of the
processing as specified in the privacy statement, but the data subject
requires them for the establishment, exercise or defence of legal claims.
The data subject has objected to the processing of the personal data,
pending the verification whether the legitimate grounds of the controller
override those of the data subject.

The request must contain the data subject’s name and identity number, as well as a specific and justified request for restriction.

16. Retention periods and data erasure rights

Ilmarinen retains personal data in operations based on its statutory obligation. The retention periods are determined in accordance with earnings-related pension legislation or other applicable legislation:

Personal data linked to insurance: validity of the insurance and ten
subsequent calendar years
Personal data linked to pension and rehabilitation matters: the lifetime of the insured and five subsequent calendar years
Personal data linked to survivors’ pension: survivors’ pension payment
period and five subsequent calendar years
Personal data for the collection of late insurance contributions: up until the end of the collection and five subsequent calendar years
Personal data linked to appeals: 50 years if they do not need to be
retained for a longer period based on the above points.

In non-statutory operations, Ilmarinen must retain personal data for as long as any one of the processing grounds presented in section 4 of this privacy statement is valid and the personal data is necessary for its purposes. Once the retention period of personal data has expired and there are no other grounds for processing the data, the data will be erased or anonymised.

Telephone recordings are retained for 6-12 months.

Personal data shall also be erased, if necessary, when the data subject objects to the processing of personal data based on a legitimate interest, and there are no other grounds for the processing.

17. Right to appeal to a supervisory authority

The data subject is entitled to bring the matter before the Data Protection Ombudsman, if the data subject considers that the processing of the personal data that apply to him/her breach the relevant legislation.

18. Principles of register protection

At Ilmarinen, information security and the protection of personal data are an integral part of the information systems’ functionality and data architecture. Requirements for the information systems’ security and the integrity, confidentiality, availability and continuity of the data processing are always established beforehand when the systems are designed. Ilmarinen processes all personal data securely and pursuant to legislation and develops and inspects information security systematically.

Privacy statement of Ilmarinen’s customer register updated 13 September 2023.