Official documents shall as a basic principle be in the public domain pursuant to the Act on the Openness of Government Activities (621/1999). The Act on the Openness of Government Activities applies to publicity and secrecy of documents in the possession of, or registers maintained by the National Land Survey of Finland and to granting access to these documents and registers.
A person can present a request concerning secrecy of contact information to the National Land Survey of Finland. Such request shall be made pursuant to section 24, subsection 1, paragraph 31 of the Act on the Openness of Government Activities. Pursuant to this paragraph official documents containing information on a secret telephone number given by a person or information on the location of a mobile communications device, and documents containing information on the person’s domicile, place of residence or temporary place of residence, telephone number or other contact information, shall be kept secret, if the person has asked for the information to be kept secret and he or she has a justified reason to believe that his or her own health or safety or that of his or her family are in jeopardy.
The contact information shall be kept secret for 50 years after the death of the person whom the document concerns or, if the time of death is unknown, for 100 years, pursuant to section 31, subsection 2 of the Act on the Openness of Government Activities.
The National Land Survey of Finland may grant another authority access to an address or other contact information which is secret contact information pursuant to section 29, subsection 2 of the Act on the Openness of Government Activities.
The request and the target time for processing the request
The request concerning secrecy of contact information addressed to the National Land Survey of Finland can be made by free form or by using the below mentioned electronic form. A request by free form must be signed by hand. A request by free form including grounds shall be sent in writing by mail or shall be scanned and sent by encrypted e-mail to the address of the Registry of the National Land Survey of Finland which is kirjaamo@nls.fi. Please notice that an ordinary, unencrypted e-mail is not data secure. You can use the Securedmail-service to send encrypted e-mail.
Fill in the request form concerning secrecy of contact information (available in Finnish) (available in Swedish)
The request and the processing of the request at the National Land Survey of Finland are free of charge.
A decision concerning the secrecy issue will be given without delay. The target time for processing the request is two weeks from the time of receipt of the request, or if additional information is requested concerning the issue, two weeks from the time when the requested additional information is available.
If the request concerning secrecy of contact information is accepted, the contact information of the person in question shall be marked as secret in the registers maintained by the National Land Survey of Finland that contain contact information that pertains to the request. If the object of the request is a document in the possession of the National Land Survey of Finland that contains such contact information, the document in question shall be marked as secret.
The secrecy concerning contact information shall only apply to a document in the possession of, or a register maintained by the National Land Survey of Finland that contains contact information at the time of receipt of the request pursuant to the Act on the Openness of Government Activities.
If a person delivers a new document to the National Land Survey of Finland that contains contact information after the time of receipt of the request concerning secrecy of contact information, or if the National Land Survey of Finland stores contact information from a person into a register maintained by the National Land Survey of Finland after the time of receipt of the request concerning secrecy of contact information, the person in question may present a new request concerning secrecy of contact information regarding the document or register in question to the National Land Survey of Finland. The previous request concerning secrecy of contact information and the decision given concerning the request, apply only to the documents and information that were in the possession of the National Land Survey of Finland at the time of receipt of the request as referred to above.
The grounds for the request concerning secrecy of contact information
In order for the National Land Survey of Finland to declare the contact information secret, the National Land Survey of Finland must receive documentation from the presenter of the request showing that as a consequence of access to the contact information in question the presenter of the request has a justified reason to believe that his or her own health or safety or that of his or her family are in jeopardy. The National Land Survey of Finland must establish whether there are such grounds for the secrecy that are required by law.
The presenter of the request does not have the responsibility to provide the National Land Survey of Finland with written evidence about the health or safety related threat. The presenter must however invoke the concrete grounds, based on which the existence of the threat can be evaluated by the National Land Survey of Finland in an objective way during the decision evaluating phase.
The object of the request
The National Land Survey of Finland maintains certain essential, national registers. These are the title and mortgage register, the cadastre, the private road register, the public purchase witness register, the official purchase price register, and the register of housing company shares. Information on, inter alia, title to real estate, mortgages and special rights is entered into the title and mortgage register, information on real estates is entered into the cadastre, information on private roads is entered into the private road register, information on public purchase witnesses is entered into the public purchase witness register, information on conveyance of real estate is entered into the official purchase register and information on, inter alia, the possession and pledging of housing company shares and restrictions on housing company shares is entered into the register of housing company shares.
Information service concerning information in the title and mortgage register, the cadastre and the private road register is provided through the Land Information System pursuant to the Act on the Land Information System and Related Information Service (453/2002). Access to information in the public purchase witness register is provided pursuant to the Act on Public Purchase Witnesses (573/2009). Information service concerning information in the official purchase price register is provided pursuant to the Act on the Official Purchase Price Register (552/1980). Information service concerning information in the register of housing company shares is provided pursuant to the Act on the Residential and Commercial Property Information System (1328/2018).
The information in the title and mortgage register, the cadastre, the private road register, the public purchase witness register, the official purchase price register, and the register of housing company shares, is as a basic principle in the public domain pursuant to the act on the register in question or the Act on the Openness of Government Activities that complements the aforementioned act. However, insofar as there is such information in these registers that is classified secret in accordance with applicable law, the information in the registers is secret. Contact information concerning people can, where this is necessary, be inserted into these registers. It is possible that there is contact information concerning people also in other registers maintained by the National Land Survey of Finland. Although information service is not provided concerning these other registers, the Act on the Openness of Government Activities also applies to these registers. The National Land Survey of Finland grants access to information in the registers maintained by it only in accordance with applicable law.
Secrecy pursuant to section 24, subsection 1, paragraph 31 of the Act on the Openness of Government Activities applies, in accordance with the definition of a document pursuant to section 5 of the said act, to documents in the possession of the National Land Survey of Finland or to registers maintained by the National Land Survey of Finland. The presenter of the request is responsible for individualizing the document or register pursuant to applicable law, which is the object of the request concerning secrecy of contact information. The secrecy is specific to the document or register, and it will be applied only when granting access to the document or register in question. The object of the request concerning secrecy of contact information can, inter alia, be all registers maintained by the National Land Survey of Finland.
The secrecy does, on the other hand, not apply to all personal data, but only to such information concerning the person’s domicile, place of residence or temporary place of residence, telephone number and other contact information, that shall be kept secret pursuant to the Act on the Openness of Government Activities. Therefore, the name or personal identity code of a person that appears on the certificate of title from the title and mortgage register cannot be bound by the secrecy concerning contact information. However, the name and personal identity code of a person who is the holder of housing company shares in the register of housing company shares are bound by the secrecy concerning contact information, since in most cases it is possible to establish the place of residence of a person based on this information. In this case access to the information concerning the person that is the holder of the shares, and which information is entered into the list of shares, can be granted only to an authority that or a person who can prove that the information is necessary for exercising its, his or her rights pursuant to chapter 2, section 15, subsection 5 of the Limited Liability Housing Companies Act (1599/2009).
Non-disclosure for personal safety
The abovementioned secrecy pursuant to section 24, subsection 1, paragraph 31 of the Act on the Openness of Government Activities applies only to the authority, to which the person has presented the request concerning secrecy of contact information. It should be noted that the secrecy of contact information is not the same as non-disclosure for personal safety reasons provided by the Digital and Population Data Services Agency. Pursuant to section 36, subsection 1 of the Act on the Population Information System and the Certificate Services of the Digital and Population Data Services Agency (661/2009) the Digital and Population Data Services Agency can record a non-disclosure for personal safety for a person in the Population Information System, if the person has justified and obvious reason to believe that his or her own health or safety or that of his or her family are in jeopardy.
If a person has been granted a non-disclosure for personal safety by the Digital and Population Data Services Agency, contact information pertaining to the non-disclosure for personal safety shall not be transferred from the Population Information System to the registers and systems maintained by the National Land Survey of Finland. Therefore, the address of a person in the Population Information System shall not for instance be transferred to the title and mortgage register, and therefore it does not appear on the certificate of title from the title and mortgage register. If one of the holders of the title to a real estate unit has been granted a non-disclosure for personal safety, neither the address of this holder of title nor the addresses of the other holders of title appear on the certificate of title of the real estate unit in question. Correspondingly, the same address shall not be transferred to the register of housing company shares, and the name, personal identity code and contact information of the person that has been granted the non-disclosure for personal safety, do not appear on the printout of owner apartments, the list of shares or the list of contact information of the holders of the shares provided to the housing company. If one of the holders of the shares has been granted a non-disclosure for personal safety, neither the name, personal identity code or contact information of this holder of the shares, nor the names, personal identity codes or contact information of the other holders of the shares appear on these printouts. The same principle concerning the information that appears on the certificates and other printouts applies also to the secrecy of contact information referred to above. However, the other non-disclosure orders concerning contact information in the Population Information System are not transferred from the Population Information System to the title and mortgage register and the register of housing company shares.
Additional information on non-disclosure for personal safety is available on the website of the Digital and Population Data Services Agency.
Although a person has been granted a non-disclosure for personal safety, there might be documents containing his or her contact information in the electronic archive of the National Land Survey of Finland. There might also be documents containing contact information that come from another document, from the person in question or from a third person, in a register or system maintained by the National Land Survey of Finland. The non-disclosure for personal safety referred to above does not apply to this contact information. A person may present a request concerning secrecy of contact information in a certain register or document as referred to above, irrespective of whether the person has been granted a non-disclosure for personal safety.
Access to contact information for purposes of direct marketing, polls or market research is not granted
Pursuant to section 16, subsection 3 of the Act on the Openness of Government Activities the National Land Survey of Finland may not grant access to personal data for purposes of direct marketing, polls or market research, unless access for such purposes is specially provided otherwise or unless the data subject has consented to the same.
The prohibition of access to information pursuant to section 16, subsection 3 of the Act on the Openness of Government Activities applies also to persons that have not requested that their contact information shall be kept secret. Therefore, the National Land Survey of Finland shall not as a basic principle grant access to contact information in documents in the possession of, or registers maintained by the National Land Survey of Finland for the purposes referred to above.