Privacy policy for calls, AI and WhatsApp recordings

VAV Group’s Privacy Notice on Call, Chat and WhatsApp Recordings.

1. Contact details of the data controller for data protection matters

Data controllers

The data controllers are the housing companies owned by the VAV Group companies listed below, each in respect of their own residents’ register; hereinafter referred to as the “Data Controller” or “VAV”.

VAV Yhtymä Oy (business ID 0640915-7) and its subsidiaries listed below,

  • VAV Asunnot Oy
  • VAV Palvelukodit Oy
  • VAV Hoiva-asunnot Oy

Contact details for data protection matters 

email: tietosuoja@vav.fi

Address: VAV Yhtymä Oy, Data Protection, Veturikuja 7, 01300 Vantaa

2. Data subjects and the content of the register

Data subjects are customers who contact customer service, as well as customer service staff who respond to enquiries.

The following details are recorded from calls:

  • the name or ID of the VAV employee or subcontractor’s employee who received or made the call
  • the caller’s telephone number, customer ID, first name and surname
  • the date, start and end times, and duration
  • the content of the call as an audio recording

The following data is recorded from chat conversations on the website:

  • the name or ID of the VAV employee or subcontractor’s employee who handled the chat conversation
  • date, start and end times, IP address, browser and operating system.
  • conversation ID
  • the content of the conversation

The following data is recorded from WhatsApp conversations:

  • The name or ID of the VAV employee or subcontractor who handled the WhatsApp conversation (WhatsApp does not process employee data.)
  • the customer’s mobile phone number
  • chat event tracking data, e.g. the date and time of messages and their content being sent, delivered, received and read
  • the content of the conversation.

3. Legal bases and purposes of personal data processing

The data controller processes the personal data of data subjects as follows:

Applicants for VAV housing, tenants and other residents (customers) may contact VAV’s customer service in the manner of their choice – by telephone, via chat or via WhatsApp. VAV records telephone, chat and WhatsApp conversations with its customer service team so that interactions, communications and the matters discussed therein can be verified in order to safeguard the rights and legal protection of customers and VAV. In addition, the recordings are used to ensure the quality of VAV’s customer service, to provide guidance and training for staff, to prevent and investigate misconduct, to maintain and develop customer service and its systems, and for statistical purposes.

The legal basis for processing the recordings is VAV’s legitimate interest, which, in the case of housing applicants, is based on the applicant relationship, in the case of tenants, on the tenancy relationship; in the case of residents, on the tenancy relationship; and in the case of VAV’s employees, on the employment relationship (Article 6(1)(f) of the EU General Data Protection Regulation).

4. Where data is collected from

Customer data relating to recordings is collected from telephone, chat and WhatsApp conversations, as well as from the registers of housing applicants, tenants and residents. Data on VAV employees or those of its subcontractors is collected from VAV’s customer service information systems.

5. To whom is the data disclosed or transferred for processing

VAV does not disclose data from recordings to external parties without the data subject’s consent, unless this is necessary for the prevention and investigation of misconduct by the police and other investigative authorities, to deal with legal requirements, e.g. to legal advisers and courts, or to fulfil VAV’s statutory obligations.

VAV uses subcontractors in the processing of personal data in accordance with this privacy notice. In such cases, personal data may be transferred to subcontractors to the extent necessary for the subcontractor to perform its services. Subcontractors process personal data on behalf of and for the account of VAV in accordance with its instructions. Subcontractors are bound by agreements concluded with VAV regarding the processing of personal data, including provisions on confidentiality and data security. VAV uses the following subcontractors for the processing of stored data:

  • Call Waves Solutions Finland Oy: customer service tasks, e.g. phone calls, chat, WhatsApp conversations
  • Visma Sirius Oy: chat service system
  • Avy AB: housing services provided by an AI assistant; 24/7 customer support, fault reporting and automatic processing of service requests, assisted by the AI assistant “Veiko”.

Use of the AI assistant 

An AI-based chat service (the AI assistant “Veikko”) is used to handle service requests in the customer register maintained by the data controller and via the OmaVAV service’s customer service.  The AI assistant processes limited personal data entered by the data subject in the chat and obtained from the customer register maintained by the data controller: name, address details and information relating to the building. The processing of personal data is based on the data subject’s consent to use the AI assistant.  

The AI agent utilises AI technology from a third-party service provider (Azure OpenAI), which is hosted on a cloud service located within the European Economic Area. The processing of personal data is carried out in accordance with applicable data protection agreements and solely for the purposes described in this privacy notice. 

The AI assistant operating on the data controller’s website processes only the personal data provided by the data subject during the conversation. Processing is based on the data subject’s consent to use the AI assistant. The AI assistant only has access to the aforementioned data from the data controller’s customer register. 

6. Transfer of data outside the EU/EEA

VAV and its subcontractors may process personal data within the EU/EEA and in countries whose level of data protection has been recognised as adequate by the European Commission.  

If, in exceptional circumstances, personal data is processed in other countries, VAV ensures an adequate level of data protection by agreeing to the transfer using Standard Contractual Clauses approved by the European Commission.

7. Principles governing the protection of the register and data retention periods

Only those persons who require the data to carry out their work duties are authorised to access it. Access to stored data is restricted to designated personnel who maintain the customer service information systems and the data therein, as well as to customer service representatives handling customer transactions and their supervisors. Each customer service representative has access to the recorded data relating to the transactions they have handled, whilst their supervisor has access to the recorded data relating to all transactions handled by their subordinates.

The stored data is protected by personal usernames and passwords. Access and processing rights to the data are granted on the basis of job roles. Staff and subcontractors processing the data are bound by confidentiality and data security obligations. The protection of electronically stored data is based on access control, technical protection of databases and servers, monitoring of their use through the collection of log data, physical security of premises, access control, firewalls and other data communication security measures, as well as data backup.

Staff are briefed and trained on the processing of personal data through regularly organised data protection and information security training sessions.

Recordings are retained for one month, after which they are automatically deleted. Recordings may be retained for a longer period if necessary for a specific reason, for example, for the submission and processing of legal claims or due to suspected criminal offences and related official investigations.

8. The data subject’s rights to access, rectify and other rights

The customer has the right to access their personal data held in the register.

The data subject has the right to request the rectification or erasure of data that is inaccurate, out of date, unnecessary or unlawful.

The data subject also has the right to withdraw their previously given consent to the processing of their personal data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal of consent.

If the data subject has provided their personal data to the data controller and the processing is based on consent or a contract, they have the right to receive this data in a structured, commonly used and machine-readable format, and the right to transfer the data to another data controller in accordance with applicable legislation.

Where the basis for the processing of personal data is a legitimate interest, the data subject has the right to object to the processing of their data on grounds relating to their particular personal circumstances. When making such a request, the data subject must specify the particular circumstances on which the objection is based.

In situations specified by law, the data subject may request that the processing of their personal data be restricted, for example by suspending it in whole or in part, where the data subject considers there to be uncertainty regarding the accuracy of the data or its processing.

A request to access or restrict data may be made using the data request form on the VAV website. A request to rectify data may be made the OmaVAV service or via the data request form available on the website.

Data subjects have the right to lodge a complaint regarding the processing of their personal data with the Data Protection Commissioner.