Privacy Notice for Applicants for Rental Accommodation

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

Data controllers

The data controllers are the properties owned by the VAV Group companies listed below, each in respect of their own tenant 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. Applying for housing and relevant legislation

The data controller lets out rental flats built using both private funding and state support. Tenants for rental flats built with state support are selected on social grounds.

The data controller advertises all flats as available for public application on its online service at https://vav.fi/ (hereinafter referred to as the “Service”).  On the Service, applicants can view the flats on offer and complete, save, edit, submit and renew their flat applications to the data controller. The following legislation applies to the processing of personal data in this context:

  • EU General Data Protection Regulation 2016/679 (GDPR)
  • Data Protection Act 5 December 2018/1050
  • The following legislation also applies to the application process and tenant selection for state-subsidised rental housing:
  • The ARA Act 17 December 1993/1189
  • Act on Interest Subsidies for Rental Housing Loans and Right-of-Occupancy Housing Loans 29 June 2001/604
  • Arava Restrictions Act 17 December 1993/1190
  • Government Decree on the Selection of Tenants for Arava and Interest-Subsidised Rental Dwellings, 20 March 2008/166
  • Decree of the Ministry of the Environment on the public and general application procedure for Arava and interest-subsidised rental dwellings 25 February 2003/182
  • Decree of the Ministry of the Environment on the application form and its annexes for ARAVA and interest-subsidised rental dwellings 19 October 2006/904
  • Act on Short-Term Interest Subsidies for Construction Loans for Rental Housing, 29 June 2016/574
  • Government Decree on short-term interest subsidies for loans for the construction of rental housing 603/2016
  • Administrative Procedure Act 434/2003
  • Language Act 423/2003
  • Act on the Openness of Government Activities 621/1999, the Openness Act
  • Act 13/2003 on Electronic Services in Public Administration
  • Act 306/2019 on the Provision of Digital Services, the Digital Services Act
  • Act 906/2019 on Information Management in Public Administration, the Information Management Act.

3. Data subjects and the content of the register

The data controller processes the following data concerning those interested in renting flats, flat applicants and persons moving into a flat with them:

3.1 Application details, for example:

  • the application submitted by the applicant, any attachments and the applicant’s details provided therein, including name, personal identity number and contact details, as well as details of the flat being applied for
  • In the case of state-subsidised rental flats, the following additional information: marital status, nationality, type of residence permit, mother tongue, level of education, and the names and dates of birth of other people moving in
  • information regarding housing needs (e.g. details of current accommodation and living arrangements, homelessness, obligation to move, pregnancy)
  • income and assets of other household members: monthly pre-tax income (€/month), main source of income, employer or educational institution and start date, value of assets.

3.2 Information relating to contacts, for example:

  • Letters, emails, phone calls, chat messages, WhatsApp messages and other communications between the person interested in a property and customer services
  • the person’s contact details
  • information regarding the property and the person’s need for it.

3.3 Information relating to the use of the service, for example:

  • the applicant’s, i.e. the user’s, identification details (including name, personal identification number, and details of the identification process: identification method/document, person carrying out the identification)
  • Service username, password or other possible identification details, access rights; usage history recorded during use
  • the name and email address of the holder of the access rights
  • Identifiers and metadata for the application and its attachments
  • Event data relating to service use, i.e. log data, such as the time of sending/receipt of an application
  • browsing and usage data collected via cookies and similar technologies; the page from which the user accessed the Service, the device model, unique device identifier, browser version, IP address, session ID, session time and duration, as well as screen resolution and operating system, the user’s language preference and other personalisation data used to improve the usability of the Service.

4. Legal bases and purposes of personal data processing

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

 Purpose of processingLegal basis for processingPersonal data processed
Making properties available for public application and marketing on the data controller’s Service and on other organisations’ online servicesThe legal basis for processing is the Data Subject’s consent to the use of cookies and the processing of data collected through them.

With regard to ARA housing, the processing is also based on the Data Controller’s compliance with its statutory obligations, as set out in the legislation referred to in paragraph 2.
Information concerning the use of the service
Responding to enquiries regarding flats, providing information on vacant flatsThe basis for processing is the Data Controller’s legitimate interest based on the customer relationship (Article 6(1)(f) of the GDPR)Information relating to enquiries
Tenant selectionWith regard to privately funded housing, the legal basis for processing applicants’ data is the legitimate interest based on the applicant relationship, Article 6(1)(f) of the TSA

With regard to ARA dwellings
, processing is based on compliance with the data controller’s statutory obligations, as set out in the legislation referred to in paragraph 2.

The processing of health and other data falling within special categories of personal data is based on Section 6(1) 2), i.e. this concerns processing that is provided for by law or arises directly from a task assigned to the data controller by law.
Application data
Identification of service users;

Ensuring the functionality and availability of the service and investigating disruptions;

Demonstrating the accuracy of data processing within the service;

Ensuring the information security of the service
For applicants for privately funded housing, the basis for processing is the statutory obligation regarding the security of personal data processing, Article 32 of the TSA

For ARA housing, processing is also based on compliance with the data controller’s statutory obligation, Section 6 of the Act on the Provision of Digital Services, and Chapter 4 of the Act on Information Management in Public Administration
Information concerning the use of the service
Provision, management and development of the service; monitoring and allocation of usage volumes and costs; compilation of statisticsThe data controller’s legitimate interests (Article 6(1)(f) of the GDPR) in carrying out and developing its activities
User consent for data collected via non-essential cookies.
Information relating to the use of the service

The data controller checks the credit history of applicants whose housing applications it has approved in the credit information register maintained by Suomen Asiakastieto Oy for the purpose of concluding a tenancy agreement. Credit information is not stored in the applicant register. In the case of state-subsidised rental accommodation, payment default entries in credit records do not in themselves constitute an obstacle to selection, but outstanding rent owed to the data controller may require, for example, a documented repayment plan, a subletting agreement negotiated with the social welfare authorities, or a payment undertaking.

Data in the register is not processed for the purposes of automated decision-making or profiling.

5. Where is the data collected from?

The data controller primarily collects data from the data subject themselves or from a person authorised by them via the housing application and its annexes, in additional information requested by the data controller, and from data provided in other personal or electronic service interactions.

In addition, data on the use of the Service is collected automatically via cookies.

The data controller checks the credit history of applicants whose housing applications it has approved against the credit register maintained by Suomen Asiakastieto Oy, as well as the population register details of all persons included in the application. Applicants’ identification details are collected from the identity verification service provider when the applicant authenticates themselves on the Service.

6. To whom is the data disclosed or transferred

The data controller discloses the personal identification number of the selected housing applicant to Suomen Asiakastieto Oy and the Digital and Population Data Services Agency for the purpose of checking credit information and population register data. The data controller will not otherwise disclose data to external parties without the data subject’s consent, unless this is necessary to fulfil the data controller’s statutory obligations, for example to local authorities responsible for supervising the selection of tenants, as well as to data protection, police, pre-trial investigationand prosecuting authorities, as required by them.

The Data Controller uses subcontractors for the processing of personal data in accordance with this policy. 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 the Data Controller in accordance with its instructions. Subcontractors are bound by agreements entered into with the Data Controller regarding the processing of personal data, including provisions on confidentiality and data security. The Data Controller uses the following subcontractors for the processing of stored data:

Third parties monitoring internet and mobile services on behalf of the data controller may also collect data via cookies for their own use in accordance with their own terms and conditions. They are responsible for their own cookies and for the data they collect for their own use.

7. 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 cases, personal data is processed in other countries, VAV will ensure an adequate level of data protection by agreeing to the transfer the Standard Contractual Clauses approved by the European Commission.

8. Processing of personal data relating to users of the data controller’s social media

The Data Controller’s website utilises social media features (i.e. social media plugins) such as Facebook buttons, which link to the Data Controller’s social media pages.

Social media services share users’ data with the data controller in accordance with their privacy policies and the consent given by users, e.g. comments and links relating to the data controller’s websites that users share on social media, as well as information contained in the user’s public profile. The data controller processes personal data obtained via its social media pages on the basis of a legitimate interest solely for the data controller’s own purposes, such as informing users about new products, services or offers, organising competitions and prize draws, receiving feedback, purchasing advertising on social media platforms, measuring the reach of pages or adverts, or providing customer service on community pages. The data controller does not process data outside of social media, nor is the data shared by social media platforms combined with the data controller’s other data or registers without the user’s consent.

Community plugins are the responsibility of the company providing them. They are primarily responsible for compliance with data protection legislation, data security and the realisation of data subjects’ rights within the service. The data controller acts as a joint controller with Facebook with regard to the data of users of the data controller’s community pages. You can familiarise yourself with the social media platforms’ privacy policies and information regarding joint controllership, and manage your privacy settings on a service-by-service basis.

Facebook and Instagram / Meta

9. Principles of data protection and data retention periods

Data is protected by personal usernames and passwords. Access to and the right to process data are granted on the basis of job roles. Staff and subcontractors processing the data are bound by confidentiality and data security obligations. Information contained in ARA-asuntojen housing applications is confidential under Section 24 of the Freedom of Information Act. 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 in the processing of personal data through regularly organised data protection and information security training sessions.

Applicants can view and edit the details of their submitted application only by logging in with strong authentication, such as bank credentials.

The data controller retains the data in the register for the 4-month validity period of the application and, thereafter, for as long as the applicant renews the application during its validity period.

Applications, including any attachments, from applicants who have been allocated a flat are retained for three years from the date of approval.

Applications that have not resulted in the allocation of a flat (including withdrawn applications) are retained for three years from the date the application was submitted.

If an application does not result in the conclusion of a tenancy agreement and relates to privately funded housing, personal data will be deleted within three (3) months of the application’s validity period ending.

Data relating to the use of the Controller’s Service is retained for 2 years from the date on which access rights are revoked.

Where consent has been given, data may be processed for as long as the data subject’s consent remains valid.

Usage data for electronic services collected via cookies shall be deleted in accordance with the time limits specified in the cookie consents.

Anonymised data (for example, aggregate data) may be retained indefinitely.

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

Data subjects have the following rights under the General Data Protection Regulation:

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.

Data subjects also have the right to withdraw their 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. The data subject must specify the particular circumstances on which their objection is based when making the request.

In circumstances 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 via the data request form available on the VAV website. A request to rectify data can 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.

29 September 2026