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DPA case 3116/163/20 – Violation Found (Finland, 2023)

Violation Found
DPA Tietosuojavaltuutetu18 January 2023Finland
final
Violation Found

Privacy enforcement record

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A preschool in Finland asked parents for personal information to help manage childcare during COVID-19. However, many parents were misled into thinking they had to provide this information, which raises concerns about consent. This case highlights the importance of clearly communicating the voluntary nature of data collection.

What happened

The preschool required parents to return a form with personal data, including children's social security numbers, under the impression it was mandatory.

Who was affected

Parents of children attending the preschool who were asked to provide personal information.

What the authority found

The DPA found that the preschool did not clearly communicate that returning the form was voluntary and that they lacked a valid legal basis for processing certain personal data.

Why this matters

This case emphasizes the need for organizations to be transparent about data collection practices. Schools and childcare providers should ensure parents understand their rights regarding personal data.

Recorded legal citations
Automatically processed
Art. 13 GDPR
Art. 5(1)(a) GDPR
Art. 12(1) GDPR
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Art. 5(1) GDPR
Art. 12(1) GDPR
Art. 13(1)(c) GDPR

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Secondary-source text retrieved.

Automated check recorded — 18 October 2026.

Processing notes: articles corrected.

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Full Legal Summary
Detailed

On April 2020 an early childhood education unit (pre-school) sent an inquiry along with an informational letter regarding activities to prevent the spread of COVID-19. The families were asked to return the form, providing personal data (including the child's social security number) and stating whether they could arrange childcare at home during the pandemic. A letter accompanying the inquiry form stated that handling personal data is based on consent and that the data subject gives consent by returning the form. In reality many parents were told that returning the questionnaire was mandatory. The controller responded to the DPA's request for information, stating that returning the inquiry form was voluntary but strongly desirable. The information was needed to arrange activities during exceptional circumstances due to the COVID pandemic. The controller agreed that the voluntary nature of the inquiry could have been more clearly communicated. They also explained that employees had been given general guidelines for handling personal data, but not specific guidelines for this particular situation. The controller identified Article 6(1)(c) GDPR (necessary for compliance with a legal obligation) as the legal basis for the processing of personal data in this case. Their statement asserted that they needed the information in order to arrange day care for children, accounting for the number of students learning from home, and to arrange lessons in small groups where possible. They also claimed that they required the information in order to refund families if a child was not attending the activities due to the pandemic. However, the controller agreed that a child's social security number was not a necessary piece of information, and that their age would have been enough to verify the identity of the child. The DPA considered whether data subjects were informed in the survery of the purpose and legal basis of the processing of personal data, and the voluntariness of resp

Outcome

Violation Found

The DPA found a violation but did not impose a fine.

Related Enforcement Actions (0)

No other enforcement actions found for DPA case 3116/163/20 in FI

This is the only recorded action for this entity in this jurisdiction.

Details

Decision Date

18 January 2023

Authority

DPA Tietosuojavaltuutetu

GDPRhub ID

gdprhub-5658

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. DPA case 3116/163/20 - Finland (2023). Retrieved from cookiefines.eu

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