1. Data controller

KAS Housing Ltd (Business ID: 1656611-3)

Toinen linja 14,

00530 Helsinki

Tel. (09) 771 2777

  1. Person in charge of data registers

Housing manager

Toinen linja 14,

00530 Helsinki

Tel. (09) 771 2777

tietosuoja@kas.fi

  1. Name of the data file

Data file based on a customer relationship with KAS Housing Ltd or other factual connection

  1. Purpose of use of personal data

The processing of personal data is based on a legitimate interest of the company and/or a customer relationship, other factual connection, consent given by the customer, customer relationship management, analysis and development, such as:

– maintenance of customer data

– maintenance of rent ledgers

– customer surveys, such as customer satisfaction surveys

– maintenance of apartments and sharing of necessary information with maintenance companies that have a contractual relationship with the controller

– collection of rent receivables and other receivables

– termination of rental agreements

– in addition to customer communications, personal data may also be used for the planning and development of the controller’s business operations.

  1. Data content of the register

The following personal data and change details regarding housing applicants, recommended customers, tenants and co-tenants may be processed within the context of this register:

Basic information, such as

– name

– personal ID code

– contact information (postal address, telephone number, email address)

– gender

Data related to a customer relationship or other factual connection, including

– customer identification number

– start date of customer relationship

– number of people in the household

– first name, last name and personal ID code of a spouse or domestic partner who lives in the same household

– first names, last names and personal ID codes of everyone who lives in the same household

– with consent of the data subject: the first names, last names and personal ID codes of people who live in the same household

– information regarding consent given by a co-applicant to allow the data subject to provide their information to the controller

– information regarding a possible guardian

– information regarding employment and the duration and nature of the employment relationship

– information regarding income and assets

– credit information

– information regarding debt adjustment

– information regarding debt collection

– information regarding housing before customer relationship

– information regarding the need for housing

– information regarding tenancy, including information about the rental agreement, rental payments, security deposit and termination of rental agreement

– for tenants under the age of 18: identifying information of the custodian who has signed the rental agreement

– complaints, feedback and other communication and measures related to the customer relationship and factual connection, including recording of calls

– marketing measures targeted at the data subject, their use and information provided in connection to them

– bank account data related to the termination of a rental agreement

– direct marketing bans and consent

  1. Regular sources of data

Data is collected from the data subject in connection with filling out the housing application form and use of electronic services, among other things.

Personal data may also be collected and updated from other personal data registers maintained by the controller, customers terminating their tenancy,

partners of the controller and authorities and companies that offer services related to personal data, such as the Population Register Centre and credit information from the credit data register maintained by Suomen Asiakastieto Oy.

  1. Personal data storage period

The personal data of a person who has submitted a housing application shall be stored for six years after the last time that customer has submitted an application, unless the customer has signed a rental agreement.

Data related to a rental agreement may be stored for ten years after the rental agreement has been terminated and both parties have completed their obligations related to the tenancy. The same storage period applies to all people who live/lived in the same apartment and to telephone recordings and other communication/interaction with the customer.

  1. Disclosure and transfer of data

Personal data is not generally disclosed to outside KAS asunnot. Data may be disclosed within the limits permitted by the current legislation to parties such as contractual partners that perform collection activities on behalf of KAS asunnot or parties that have a legal right to access the data. The data may also be disclosed to maintenance, security and lock companies and electricity and network providers in order to perform housing-related services.

If an apartment is purchased by an external party KAS asunnot may disclose to the new owner of the apartment any data necessary to manage the tenancy.

If necessary, the data may be transferred to other EU member states or outside the EEA.

  1. Protection of the data file

Data stored in the electronic data file is protected with firewalls, passwords and other generally accepted technical means of protection.

Manually maintained materials are stored in facilities to which unauthorised access is prevented.

Only named employees of the controller and companies working for and on behalf of the controller, who have also signed a non-disclosure agreement, have access to the data included in the data file by personal access right granted by the controller.

  1. Right of access, rectification and prohibiting processing

The data subject has the right, pursuant to the Personal Data Act, to see what data concerning him or her has been stored in the data file. Any request to inspect the data must be made personally in the premises of the controller.

A person may exercise his or her right to access his or her data free of charge once per year. If requests to inspect the data can be considered manifestly unfounded or unreasonable, especially if they are made repeatedly or if several copies are requested, a fee of EUR 80 will be charged based on administrative costs, or we may refuse to carry out the request.

The data subject has the right to prohibit the processing and disclosure of his or her data for direct advertising, distance selling, other direct marketing, market surveys and opinion polls by contacting the controller.

The data subject has the right to demand incorrect data to be rectified by contacting the controller.