Example: Transfer of personal data outside the EU/EEA

  • Findata has granted a data permit concerning datasets from HUS, Pirha, and Varha.
  • According to the data permit, the data processors are employees of HUS, Pirha, and Varha.
  • The data controller of the dataset is HUS, as stated in the data permit.
  • The data is processed within Findata’s secure Kapseli environment.
  • If the data processors travel to the United States for a conference: An employee of HUS can process the data remotely via Kapseli from the U.S., as they are employed by the data controller.
  • Employees of Pirha and Varha, however, are not employed by the data controller (HUS), meaning they cannot process the data in Kapseli from the U.S. without a legal basis under Chapter V of the GDPR.