Privacy statement for phone call, chat and chatbot recordings of the PRH customer service

Controller

Finnish Patent and Registration Office (PRH)
Mailing address: Finnish Patent and Registration Office, FI-00091 PRH, Finland
Street address: Sörnäisten rantatie 13 C, Helsinki, Finland
Tel. +358 29 509 5000

Representative of controller

Ms Kirsi Lahtinen
kirsi.lahtinen(at)prh.fi
Tel. +358 29 509 5000

Data protection officer

tietosuojavastaava(at)prh.fi
Tel. +358 50 473 3129

Purpose of and legal basis for processing personal data

The purpose of processing personal data is

• to ensure the quality of the Finnish Patent and Registration Office’s (PRH) customer service and to develop the customer service
• to identify the customer when the PRH discloses details about actual beneficial owners of companies

In order to develop the PRH’s customer service, the recordings may be used to train the customer service personnel, to analyse the service level and to improve instructions.

The processing of customer contacts and the identification of customers related to the disclosure of details about actual beneficial owners are based on the controller’s statutory obligation.

Personal data and categories of data subjects in the register

The following identification details of phone calls are registered:

• Start and end time of the call
• Number of the caller
• Service number called
• Name and phone number of the official.

All phone calls to service numbers are recorded. The recordings are made in a predetermined manner. The recording starts when the call is answered and ends with an end signal.

The following details of chat and chatbot sessions are registered:

• Time of the session
• Name of the customer advisor in the chat service
  

In chat sessions, the contents of the session between the customer and the customer advisor are saved, and in chatbot sessions, the contents of the session between the automated chatbot and the customer are saved.

The contents of the chatbot’s answers are mainly collected from the PRH website and other public sources available to anyone. At the beginning of the session, customers are provided with instructions for use.

The customer is not asked any personal questions and the customer cannot handle personal matters using the chatbot service. If the customer gives numeric identification details, such as a phone number, in the chatbot service, the details are erased automatically after one hour.

If we send an SMS query to a customer who has contacted our service number by phone, the following details are registered:

• Time of the query
• The customer’s phone number
• The customer's written answers to the query

The following details are registered to identify the customers receiving details about actual beneficial owners:

• Person’s name and personal identity code

Sources of information

The data are obtained from the customer’s phone calls, chat sessions or chatbot sessions started by the customer through the prh.fi website.

The customers’ identification details are obtained from the Digital and Population Data Services Agency through the identification service Suomi.fi.

Disclosure of personal data to third parties

No data is regularly disclosed.

As an exception to this, the PRH may temporarily disclose selected recordings to a research institute to evaluate the quality of the customer service. In such a case, the research institute must commit to returning or destroying the recordings used in the analysis once the analysis is complete.

Transfer of personal data to countries outside the EU or the EEA or to international organisations

No data is transferred to countries outside the EU or the EEA or to international organisations.

Storage periods of personal data

Call recordings are stored for a maximum of 6 months and the contact history for 12 months. We began storing phone calls and the contact history on 1 October 2017. Chat and chatbot recordings are stored for a maximum of 2 years. Answers to and the contact history of SMS queries are stored for a maximum of 12 months.

Customers’ identification details are not saved in our system of phone calls, chat sessions and chatbot sessions. Identification details are saved in a customer register of information services related to beneficial owners, where the storage period is five years. Go to the privacy statement for the customer register of the information service about beneficial owners.

Profiling and automated decision-making

The registered data are not used for profiling, and no automated decision-making is performed on the data.

Right of access to personal data

The data subject has the right to check what personal data about them have been entered into the register, or to find out that there are no such register entries. The data subject can ask the controller for access to their personal data. Read our instructions on how to request access to data.

Right to rectification of data

The data subject has the right to demand that the controller rectify any inaccurate or incorrect personal data concerning them without undue delay. Read our instructions on rectification of data.

Right to restriction of processing

The data subject has the right to demand that the controller restrict the processing of data, if the data subject contests the accuracy of the personal data. The idea is to restrict the processing for a period during which the controller can verify the accuracy of the personal data.

Right to lodge a complaint with the supervisory authority

The data subject has the right to lodge a complaint with the supervisory authority (the Data Protection Ombudsman).