KAIKKONEN & SUNNARI ASIANAJOTOIMISTO | ATTORNEYS AT LAW
Kaikkonen & Sunnari Attorneys at law Ltd’s client and assignment reg- ister’s (hereafter “the assignment register”) data protection policy
1. Data controller
Kaikkonen & Sunnari Attorneys at law Ltd (hereafter “Kaikkonen & Sunnari”) Contact details:
Kaikkonen & Sunnari Attorneys at law Ltd Kasarmikatu 36
Contact details on matters concerning the register
Managing director Tuomas Sunnari Kaikkonen & Sunnari Attorneys at law Ltd Kasarmikatu 36
040 843 5022
2. Data subjects
Data about the assignments, clients related to the assignments, others participating in or re- lated to the case and opposing parties as well as data about potential clients are stored to the register.
3. Basis for keeping the register and the purpose
Kaikkonen & Sunnari processes personal data based on a client relationship, an assignment and the substantive connection associated with them and to fulfill the statutory obligations pursuant to Advocates Act (12.12.1958/496, with amendments) and Act on Preventing Money Laundering and Terrorist Financing (444/2017, with amendments).
The purpose of the assignment register is to agree on assignments, organize the pursuing, planning and realization of assignments, allocate measures to assignments, identification of clients, communication with clients and others participating in and related to the case and to detect disqualifications.
4. Personal data stored to the register
The assignment register may include the following data:
present and former clients of Kaikkonen & Sunnari as well as such potential clients that have on their own initiative contacted Kaikkonen & Sunnari or requested us to contact them;
names, contact details (postal addresses, telephone numbers, e-mail addresses), identity numbers or dates of birth and copies of identification cards of beneficiaries, representatives and contact persons of private customers and corporation clients;
possible names and contact details (telephone numbers and e-mail addresses) of other persons participating in or related to the case and witnesses;
data related to the fulfilling of the statutory obligation concerning the identification of a client;
data related to the fulfilling of the statutory obligation concerning the detection of disqualification;
assignments and the role of the data subjects in them;
subject matter, measures and invoicing data of an assignment;
the responsible lawyer of an assignment;
material collected or produced to pursue an assignment;
data concerning client funds related to an assignment; and
necessary data about the clients’ opposing parties in order to pursue an assignment,
such as names and material to which opposing parties are related to.
The assignment register may include data which belongs to special categories of personal data that are necessary for the establishment or exercise of legal claims or for defence in a judicial or an administrative procedure or in a procedure outside a court.
5. Regular data sources
Regular data sources of the data that is included in the assignment register are the data sub- jects themselves and data appearing from an assignment. Data can also be collected from authorities as well as from other reliable sources within the limits of legislation.
6. Regular disclosures of data
The assignment register’s data are not disclosed to anyone nor for any purpose unless law so requires.
In processing personal data, Kaikkonen & Sunnari may use contracting parties in which case the requirements of the legislation concerning data protection are taking care of with con- tracts.
7. Duration of the processing
Personal data are stored as long as they are needed in the notified purpose or in fulfilling statutory obligations. The board of Finnish Bar Association has given a recommendation (24.1.2019) concerning the storing and disposing of the accumulative document material regarding an assignment. The material is recommended to be stored for at least 10 years after an assignment has terminated and information regarding an assignment after this as long as it is needed for conflict checks and for legal protection of an attorney.
8. Personal data processors
Only such persons that have legitimate grounds for processing the data as part of their du- ties process the register’s data.
Kaikkonen & Sunnari may also partly delegate the processing to a third party such as help- desk and accountancy firm in which case we guarantee by contracts that personal data is processed according to the operative legislation concerning data protection and otherwise duly.
9. Principles relating to the protection of register’s data
The assignment register’s data are enacted as belonging under secrecy obligation. The data cannot be disclosed to third parties without client’s consent or express statutory prescrip- tion. Only persons participating in the realization of an assignment can use the data.
The assignment register’s data are processed by means of an automated processing. The data stored in the data system are protected with user names and passwords. Telecommuni- cations link to the data system is concealed. Paper documents related to the assignment register are retained in locked space under the continuous supervision of staff.
10. Transfer of data outside the EU
Personal data are not transferred outside the EU or outside the European Economic Area.
11. Automatic decision-making and profiling
We do not use data for automatic decision-making or profiling.
12. Rights of the data subject
The data subject has the following rights. Requests for using the rights must be done in writ- ing to the following address:
AA Tuomas Sunnari
Kaikkonen & Sunnari Attorneys at law Ltd Kasarmikatu 36
The data subject has the right to request access to the personal data and the right to re- quest rectification or erasure of personal data according to and within the limits of the applied legislation concerning data protection.
The data subject has the right to request restriction of processing or object the pro- cessing according to and within the limits of the applied legislation concerning data pro- tection.
The data subject has the right to the data portability i.e. the right to receive the personal data concerning him or her in a structured and commonly used format and the right to transmit those data to another controller according to and within the limits of the ap- plied legislation concerning data protection.
The data subject has the right to lodge a complaint with the national data protection au- thority (in Finland The Data Protection Ombudsman: www.tietosuoja.fi/en/home) or with other European Union or European Economic Area data protection authority if the data subject considers that his or her statutory rights have been infringed.