DATA PROTECTION STATEMENT FOR SCIENTIFIC RESEARCH

Introduction and description of the research project

Facilitating Electoral Participation from Abroad (FACE) is a research project conducted by the University of Helsinki which examines participation in elections and political engagement from abroad. Constituting the core of the project is a questionnaire survey in which Finnish citizens living abroad were asked, among other things, about their voting habits and opinions on the status of expatriate Finns in the Finnish political system. Data was collected through the survey from May to October 2019. To supplement the survey data, qualitative research material in various forms (audio or video interviews, email responses, other written responses) is being collected from May to December 2020. This data protection statement pertains to the qualitative research carried out in the project. (The data protection statement for the quantitative questionnaire survey is available here: https://blogs.helsinki.fi/votingabroad/about-the-project/privacy-policy/.)

The data include personal data of the participants. This statement describes how personal data will be processed in the project.

Finnish citizens living abroad with the right to vote in Finland will be invited to participate in the FACE project by registering by email at votingabroad@helsinki.fi. The invitation will be distributed with the help of the Finland Society (e.g., the Finland Bridge magazine) and on social media. Additionally, the details of the participants who submitted their contact details in conjunction with the questionnaire survey (see above) will be utilised in the data collection. After potential participants have contacted the research group (new participants) or when investigators contact people who have previously submitted their contact details (survey respondents), they are provided with information on the purpose of the study and their rights as participants.

Participation is voluntary. Participants give their consent before interviews or other storing of data is initiated. Since participants informally describe their personal experiences and opinions in oral interviews, email messages and other types of written content, the data will inevitably contain direct identifiers. In identifiable form, the data will only be processed by members of the research group and, possibly, a company specialised in transcription services, which will serve as a processor of personal data and with whom a separate agreement will be concluded on the processing of personal data. Among other things, this agreement obliges the company to keep the data confidential. Research results are always reported in a way that precludes the identification of participants.

The legal grounds for processing personal data is a task carried out in the public interest (scientific research).

If necessary, this data protection statement can be updated during the study.

1   Name of the research project

Facilitating Electoral Participation from Abroad (FACE)

2   Controller of the data file

University of Helsinki
Address: PO Box 4, Yliopistonkatu 3, 00014 University of Helsinki

3   Contact person in matters concerning the study

Johanna Peltoniemi, project director, johanna.peltoniemi@helsinki.fi,
phone +358 2941 24920

4   Data protection officer

Lotta Ylä-Sulkava, data protection officer of the University of Helsinki, tietosuoja@helsinki.fi, phone +358 2941 911 (switchboard)

5   Duration of storage of the personal data contained in the research dataset

The data will be stored until the end of the project period of the FACE project, that is, until the end of May 2021. At the end of the project, the original data will be destroyed. If the data has been successfully transcribed during the project, anonymised transcripts will be stored in the Finnish Social Science Data Archive.

6   Purpose of and legal grounds for processing personal data

The data will be used for research in social sciences as described above. Research findings will be reported in such a manner that individual respondents cannot be identified. The data collected in the questionnaire survey will be archived in anonymised form.

The processing of personal data is based on the following grounds, as stated in Paragraph 1, Article 6 of the General Data Protection Regulation of the EU (GDPR): a task carried out in the public interest, scientific research (Paragraph 3, Section 4 of the Finnish Data Protection Act).

7   Parties carrying out the study

University of Helsinki, Faculty of Social Sciences

8   Content of the research dataset

• Participant’s name
• Participant’s country and place of residence
• Participant’s email and/or other contact information
• Responses to questions on the topic of the research, including
  • Participant’s experiences of or thoughts on postal voting and its development
  • Social and political participation
  • Relationship with Finland

The data collection includes questions about what are known as sensitive personal data (data that fall under special categories of personal data according to Article 9 of the GDPR), such as political opinions, beliefs or trade union membership.

The processing of such sensitive personal data is based on Point j, Paragraph 2, Article 9 of the GDPR (processing is necessary for scientific or historical research purposes), as well as Paragraph 7, Subsection 1, Section 6 of the Finnish Data Protection Act (Paragraph 1, Article 9 of the GDPR does not apply to the processing of data for the purposes of scientific or historical research, or for compiling statistics).

9   Regular sources of personal data

Participants

10   Transfer and disclosure of data, recipients

The data can be transferred to a company specialised in transcription services, which serves as a processor of personal data and with whom a separate agreement will be concluded on the processing of personal data. Among other things, this agreement obliges the company to keep the data confidential and destroy the original data after producing the transcriptions.

11   Transfer of data outside EU or EEA countries

No personal data will be transferred or disclosed outside the EU or EEA.

12   Principles of protection for the research dataset

Personal data are processed in such a manner that only persons requiring them for research purposes are granted access. The data included in the research dataset are confidential. The research dataset is processed in data systems and it is protected by means of access control based on usernames and passwords. All user rights are personal.

13   Automated decision-making

No decisions or profiling by automated means will be carried out using the research data.

13   Right of access

The data subject has the right to know whether the University of Helsinki is processing their personal data. Additionally, the data subject has the right to know which personal details are being processed. The data subject can request an extract of their personal data used in the FACE project. The person making the enquiry is obliged to provide proof of identity and, thus, their right to verify the data.

15   Right to rectification

If there are inaccuracies in the personal data being processed, the data subject has the right to request their rectification or completion.

16   Other rights related to processing personal data

The data subject has the right to restrict the processing of their personal data under the following conditions:

1. The data subject contests the accuracy of their personal data, in which case the processing will be restricted for a period enabling the University to verify the accuracy of the personal data.
2. The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
3. The University no longer needs the personal data for the purposes of the processing, but the data subject needs them for the establishment, exercise or defence of legal claims.
4. The data subject has objected to the processing (see below), pending verification of whether the legitimate grounds of the controller override those of the data subject.

The data subject has the right to object to the processing of their personal data if the processing is based on public interest or legitimate interests. In such cases, the University can no longer process the data subject’s personal data unless the University demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. The University can also continue processing the data subject’s personal data when necessary for the performance of a task carried out for reasons of public interest.

In certain individual cases, derogations from the rights described here may be made on the basis of the GDPR and the Finnish Data Protection Act, insofar as the rights render impossible or seriously impair the achievement of scientific or historical research purposes or statistical purposes. The need for derogations will always be assessed on a case-by-case basis.

17   Application of rights

If the processing of personal data for research purposes does not require the identification of the data subject and if the controller of the data file is unable to identify the data subject, the right to verify, rectify, erase and restrict the use of personal data, as well as any notification obligations and the right to transfer do not apply unless the data subject provides additional data enabling their identification (Article 11 of the GDPR).

18   Right to lodge a complaint

The data subject has the right to lodge a complaint with a supervisory authority concerning the processing of personal data. The applicant may submit the matter for the consideration of the Data Protection Ombudsman at the Office of the Data Protection Ombudsman, PO Box 800, 00521 Helsinki. Email: tietosuoja@om.fi

 

16.6.2020