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Court case KHO:2025:86 – Court Ruling (Finland, 2025)

Court Ruling
DPA Helsinginhallinto-oi28 December 2025Finland
final
Court Ruling

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A Finnish court ruled on the processing of health data by an insurance company, stating that it violated data protection rules during the application phase. The court emphasized that applicants are not considered 'insured persons' until the insurance contract is finalized. This case highlights the importance of understanding data protection laws in specific contexts.

What happened

The court found that the insurance company improperly processed health data from applicants during the insurance application process.

Who was affected

Individuals applying for voluntary personal insurance whose health data was requested were affected.

What the authority found

The court upheld the DPA's decision that the processing of health data violated GDPR because applicants did not qualify as 'insured persons' under the law.

Why this matters

This ruling serves as a reminder for insurance companies to comply with data protection laws, especially regarding sensitive health information. It stresses the need for clear definitions of roles in data processing.

Recorded legal citations
Automatically processed
Art. 9 GDPR
Art. 9(2)(g) GDPR
View original scraped data
Art. 9(GDPR)
Art. 9(2)(g) GDPR

Original imported citations before automated processing; the processing history does not establish independent verification.

Decision AuthorityKHO
Reviewed AuthorityHelsingin hallinto-oikeus (Finland)

Source checks

Linked-source text retrieved.

Automated check recorded — 19 March 2026.

Processing notes: articles corrected, national law identified, authority corrected.

Retrieved text may be a secondary summary or an announcement. These automated statuses do not establish that the original decision was read or that the record received an independent legal review. How we check sources

Full Legal Summary
Detailed

The DPA started an ex-officio investigation into the practices of an insurance company regarding the processing of health data in connection with applications for voluntary personal insurance. During the insurance application process, the controller requested health information from healthcare providers concerning individuals applying for insurance, or individuals for whose death, illness, or injury insurance was being sought. The processing was based on Section 6(1)(1) of the Finnish Data Protection Act, which provides a national derogation from the prohibition on processing special categories of personal data for insurance activities. In a decision issued on 8 June 2022, the DPA found that this derogation did not apply at the application stage, as applicants could not be considered “insured persons” within the meaning of Section 6(1)(1). On that basis, the DPA concluded that the processing of health data violated Article 9 GDPR and ordered the controller to bring its processing operations into compliance and to cease requesting health data during the application phase. The insurance company appealed. The first instance Court upheld the DPA’s substantive assessment, reasoning that neither the wording of the Data Protection Act nor its preparatory materials supported extending the concept of “insured person” to applicants prior to the conclusion of an insurance contract. The controller then appealed this decision, arguing that the insurance derogation must also cover the application stage, given the structure and purpose of insurance law and the obligation of insured persons to disclose relevant health information before insurance is provided. The court upheld the appeal, overturning both the DPA and the first instance court’s decisions. The Court held that the concept of “insured person” in Section 6(1)(1) of the Data Protection Act must be interpreted in light of national insurance legislation, in particular the Insurance Contracts Act. Although the Data Protect

Outcome

Court Ruling

A ruling by a national court on a data-protection matter.

Related Cases (0)

No other cases found for Court case KHO:2025:86 in FI

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

Details

Ruling Date

28 December 2025

Authority

DPA Helsinginhallinto-oi

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. Court case KHO:2025:86 - Finland (2025). Retrieved from cookiefines.eu

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