- Enforcing jurisdiction
- Finland · Geography does not establish applicable law.
- Confirmed applicable legislation
- No confirmed legal basis recorded.
- Privacy topics
Court case KHO:2025:86 – Court Ruling (Finland, 2025)
Privacy enforcement record
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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.
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Processing notes: articles corrected, national law identified, authority corrected.
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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
Cite as: Cookie Fines. Court case KHO:2025:86 - Finland (2025). Retrieved from cookiefines.eu
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