1a. Data file controller
National Library of Finland
Library Network Services/e-library
PO Box 15 (Unioninkatu 36)
00014 University of Helsinki
Phone: +358 2941 911
1b. Data protection officer
Lotta Ylä-Sulkava, Data Protection Officer, University of Helsinki
Email: tietosuoja(at)helsinki.fi
2. Contact person in matters concerning data file
Joona Kutilainen-Pennanen
Library Network Services/e-library
National Library of Finland
PO Box 15 (Unioninkatu 36)
00014 University of Helsinki
Email: e-kirjasto-posti@helsinki.fi (opens a new tab)
3. Name of data file
E-library user data register
4. Purpose and justification for processing personal data
Personal data are processed to confirm customers’ places of domicile, to conclude user agreements between customers and the National Library, to update information on places of domicile from the Population Information System, and to identify users logging in to the e-library.
Personal data are also processed for keeping an automated error log and for the provision of personalised services, such as recommending books on the basis of lending activity.
For service provision, data are processed by the National Library (controller of the data file), CSC – IT Center for Science (data processor) and Digiloikka Oy (data processor).
Users’ personal data are processed in anonymous form for the compilation of usage statistics, which in turn are used to calculate lending compensation accumulated through the use of E-library materials.
The analytics system can be used on the CSC servers so that traces remain within a safe environment.
When using the service, identifying data associated with sessions (e.g., IP addresses) are temporarily stored for processing, as, in the case of any errors, are the brand, model and operating system of the device used. The data are used, without being linked to personal data, to improve the service as well as to identify and restrict errors.
The grounds for the processing of personal data are the controller’s legitimate interests, consent given by the data subject with regard to data disclosed voluntarily and the necessity of the processing for the execution of agreements to which the data subject is a party, or the implementation of measures preceding the conclusion of the agreement at the request of the data subject.
5. Content of data file
Basic user information
- Identification method used
- Personal identity code (for automated updating of place of domicile)
- Language
- Name
- Place of domicile
- Email, temporarily (if account created in a local library)
Data collected for personalised services
- Personal settings
- Reservations
- Loans
- Brand, model and operating system of the device used
- Age
Data collected for usage analytics in the analytics system
- Browser type/version
- Browser language version
- Operating system (e.g., Windows 11, Android, iOS)
- Device brand, type and model
- Display type
- Source URL
Other information
- Cached data necessary for the utilisation of the online service
6. Regular sources of data
Personal data are obtained when someone registers as a user through suomi.fi identification, and they will be kept up to date from the Population Information System in accordance with the terms and conditions of the PIS modified data interface.
7. Processing and protection of sensitive personal data
Sensitive personal data are not processed in the e-library.
8. Duration of personal data storage and removal of unnecessary personal data
Personal data will be stored for the duration of the customer relationship and no more than one year after the end of the relationship (retention period).
9. Automated processing of personal data and profiling
Personal data are not used for automated decision-making or profiling.
10. Regular disclosure of data
Data are not disclosed.
11. Transfer of data outside the EU or EEA
No data are transferred.
12. Principles of data security
The data are recorded exclusively in an electronic format. The data can be accessed only by system administrators and library main users, who are identified by personal credentials granted by the National Library. The credentials are kept current by municipalities.
13. Right of access
To check which of their personal data have been collected in the service, users must contact the service administrator, namely, the e-library unit of the National Library of Finland.
14. Right to request correction or removal of data
Users can, at any time, remove their data from the service by deleting their account. The data retention period applies.
If there are errors in the personal data collected from the Population Information System, users must contact the Digital and Population Data Services Agency directly.
If necessary, users can contact the e-library using the feedback form in the application or the feedback form on the e-library website.
15. Other rights related to processing personal data
Users have the right to subject the legality of service operations to a review by the Data Protection Ombudsman: tietosuoja(at)om.fi.