Data permits

A data permit is a fixed-term permit issued by an authority to an individual, allowing the processing of confidential materials that contain personal data.

Before applying for a data permit, please read the Permits page.

Data permit applications and their attachments are confidential. We will share necessary information with data controllers to extract data, form target groups, including applicant details.

Decisions and permits granted by the authority are primarily public. On our website, we will publish the following information for projects with approved data permits:

• date of decision
• permit validity period
• permit holder (organisation)
• project name
• brief description of the intended use for the data
• purpose of use pursuant to the Act on Secondary Use

This public information may also be shared through other communication channels.

After a permit is issued, the data is extracted by the controllers and securely sent to Findata. We then pre-process, pseudonymise and, where necessary, combine and anonymise the data.

In practice we remove all the direct identifiers and create a pseudo ID, which will allow different people to be identified from one another and information on each individual can be combined from various pieces of data.

If you need data on individuals from just one public sector controller, contact the controller directly. Contact information is available e.g. on the Data page.

Processing of data permit applications

We review all data permit applications within one week of receipt and categorize them into two groups:

• Applications ready for processing: These applications contain all necessary information and will proceed to the next step. We will email the applicant within approximately two weeks if their application is eligible for processing.
• Applications requiring supplementation: These applications require additional information. Findata’s specialist will contact the applicant with detailed instructions and a request for the needed supplements.

Use the instructions and criteria provided below to complete your data permit application. You can also review and update your application before we reach out to you.

If you need to supplement an application you’ve already submitted, email us at info@findata.fi. In the subject line, write “Return of Application” and include your application’s record number (e.g., Return of Application THL/XXXX/14.0X.00/202X).

Submit an application in our e-service (asiointi.findata.fi) using either Suomi.fi e-Identification or Haka login. For more information on logging in, visit the Login page.

Please use the same identification method each time you log in to view your submitted applications and decisions.

Data permit applications can be submitted in Finnish, Swedish, or English.

1 Public information about the project

• Project name
  • The name of the project granted a data permit will be published on Findata’s website. Ensure the project name does not include confidential information.
• A brief description of the project
  • Provide a concise description of the study or project and the intended use of the requested data. This description, once the data permit is granted, will be posted on Findata’s website. Avoid including confidential details in this description.

2 Details of the applicant

• The applicant is the person or organization named in the application to whom the data permit will be issued.
  • Enter the contact person’s information only in the next section.
• Enter the applicant’s business ID. If the applicant is an individual, enter 123 in the field. For organizations located in an EU/EEA country other than Finland, provide the name of the official register where the organization is registered.

3 Details of the contact person

• The contact person is the individual responsible for answering enquiries concerning the application. Their contact details may be shared with the data controller if additional information is needed during processing.
• Describe the contact person’s relationship with the applicant, such as employment or a public service appointment.

4 Invoicing details

• E-invoicing is the primary method of invoicing.
• If the invoiced party is different from the applicant, clarify this in the ‘Additional Information’ section if necessary.
• Invoicing details for Finnish payers:
  • Use the business ID to form the VAT number. Add the country code “FI” to the beginning and remove any hyphen (e.g., business ID “1234567-8” becomes VAT number “FI12345678”).
  • Check verkkolaskuosoite.fi for e-invoice addresses.
• Invoicing details for foreign payers:
  • Foreign payers should have a Peppol address for e-invoicing. For more information, visit peppol.org.
  • If the payer doesn’t have a Peppol-address, the invoice is sent by mail.

5 Purpose of data use

• The application must clearly outline how the requested data will be used, ensuring it aligns with the purpose specified under the Secondary Use Act.
• The data you request should be relevant and necessary for the stated purpose of processing personal data.
• For the reduced decision price applicable to theses, the thesis must be at least the final assignment for a Bachelor’s degree. The reduced price only applies to individual theses.
  • If the thesis is part of a larger project or if multiple theses are produced within the same project, it should be categorized as a research project rather than a thesis work in the Findata application.

Click to see more information about different use purposes:

6 Requested data set

• The data set requested in the data permit application must be clearly described, specifying which data sets the application pertains to. This detailed description is known as the extraction description.
• The extraction description should focus solely on the necessary volume of personal data, adhering to the principle of data minimisation as outlined in the EU’s General Data Protection Regulation (GDPR). The application should provide a clear rationale for why the requested data are required for the stated purposes.
• Define the formation and criteria of the target group using the extraction description form. See more information the form below in the section ‘6.3 Extraction description’.
  • Download the extraction description form (Word-file, 51,2 kb).
• Do not attach an existing target group, controls, relatives or completed consent forms to the application.
• On the extraction description form, provide the following information regarding the final payer of the invoice:
  • Name
  • VAT ID
  • Country

6.1 Defining the extraction criteria for the target group

• The target group refers to individuals whose data will be extracted based on the data permit applied for.
• Extraction methods:
  1. The target group is formed based on selection criteria provided in the application from a data controller under the Secondary Use Act.
     • Select ‘The target group is formed according to the selection conditions described below, based on the data permit you are applying for.’
     • This applies to most cases.
  2. The target group has already been formed.
     • Select ‘The target group has been formed and the permit applicant or someone else submits the personal identity codes of the target group to Findata.‘
     • Specify the data permit under which the target group was formed and whether it is still valid.
     • This option also applies if the target group is formed based on consent.
     • If the permit for the target group is pending or under review elsewhere, provide the available details.
     • If you already have a permit for part of the target group and are applying to include additional individuals, select both of the above options.
  3. The target group is to be selected from Findata’s ready-made dataset.
     • Indicate Findata as the data controller and specify the name of the data set in the application’s table and extraction description form (e.g., Findata and FinRegistry ready-made data set).
• Note that a research permit from an organization generally permits conducting research, while a data permit specifically allows the use of personal data in the research. If uncertain, contact the permitting authority for clarification.
• If the size of the target group is unknown, contact the data controllers and/or estimate the size rather too large than too small.
• Clearly describe how the target group is formed. Ensure the target group is restricted according to the purpose of use.
  • Pay attention to which registers and criteria are used for selecting the target group. For instance, geographical boundaries might refer to the place of residence, place of birth, place of work, or place of service use.
• The data extraction will be carried out based on the selection criteria you have described in the application. Errors in describing the criteria for the target and control groups can significantly impact the usability of the data.

6.2 Defining the extraction criteria for controls and relatives

• Provide a clear description of how controls are extracted for your study:
  • Specify the registers from which controls are selected.
  • Define the criteria used to identify and match controls. This may include factors like age, gender, location, or health status.
  • Indicate how many controls are selected for each study subject.
• Provide a clear description of how relatives are extracted for your study:
  • Specify the registers from which relatives are selected.
  • Define the criteria used to identify relatives. If necessary, specify the relationship (e.g., biological vs. adoptive parents).
• If the controls and/or relatives are to be selected from Findata’s ready-made data set, indicate Findata as the data controller and the name of the data set as the register.
  • Findata will assess separately whether the control extraction can be implemented from the ready-made dataset.
• Do not attach data to the application. After the data permit is granted, Findata will provide instructions for secure data delivery. For additional guidance, refer to the page on Data transfers to Findata.

6.3 Extraction description

• Purpose of the extraction description:
  • To grant the permit, we need a detailed, register-specific list of variables for all requested data and the time period from which the data will be extracted.
  • This description ensures compliance with the principle of data minimization according to the EU’s General Data Protection Regulation (GDPR).
  • The information should be clearly articulated, focusing only on the necessary amount of personal data required for the study.
• Provide this information on the extraction description form:
  • Download the form: Extraction description form (Word file, 57 kB)
  • Include detailed variable information for controls and relatives.
  • Complete a separate form for each data controller.
  • Mention age- or gender-related data if required and specify the register.
  • If the extraction involves multiple stages, describe the extraction order.
  • If the extraction involves multiple target groups or additional data for controls/relatives, specify which data will be extracted for each group.
  • If you want to combine other data with the information requested in the application, do not describe them here, but in the next section ‘7 Other Data to be Combined’.
• Contact data controllers to review and confirm the extraction description before submitting the application to Findata.
  • The data controller will also provide an estimate of the extraction costs. Note that even if you do not receive cost estimates from the controllers in advance, you can still send your application and the extraction description form to Findata.

7 Other data to be combined

• It is possible to combine other data you possess or data obtained from other sources with the register data requested in the data permit application.
• If the target group is provided to Findata and is defined based on another permit, select “Yes” to the question “Will the data you are applying from Findata also be combined with data you have already obtained or data from other sources?”
• Provide details about each data set to be combined:
  • List the data sets and their sources.
  • Indicate if the data is in a structured form, or if it consists of images, text, or other formats.
  • Specify which target group the data sets were formed for.
  • Describe in a free-form manner, e.g., “target group / data obtained with Kela / Health Care District’s data permit / survey data.”
• Ensure all data permits for the combined data sets are valid at the time of data processing and granted for the same project.
• If the data was collected with consent, attach a template of the consent forms for the target group. Do not attach completed consent forms.
• If you plan to apply for permits from other authorities but have not yet done so, indicate this in the section “Other pending permits applications.”
• Provide more details about other data sets or any special considerations in the additional information section. If precise information cannot be provided in the table, estimate on the higher side.
• Do not attach the data to this application. Once the data permit has been granted, Findata will provide instructions on how to deliver the data securely.

8 Data processing

• Individual-level data is processed in a secure processing environment (SPE), primarily in a pseudonymized form.
• The data is primarily delivered to Kapseli, a SPE provided by Findata. If you wish to process the data in another SPE, justify why this is necessary for the project.
  • Other service providers’ SPEs can be found in the Astori register maintained by Valvira. Use the official name of the environment, which can be found in the Astori register.
  • Read more: Astori register (valvira.fi)
• If the data needs to be retained after the analysis, the data permit must be valid, and retention is only possible in a secure environment.
  • Example: If the data usage period is until December 31, 2027, and retention is needed for five years after that, the permit will be granted until December 31, 2032. Apply for a amendment of the data permit if analysis or retention beyond this period is required.
• Findata retains the pseudonymization key and the extraction criteria and documentation used to create the dataset so that the data can be reproduced if necessary.
• Processing personal data from abroad constitutes data transfer, even if the data is in a remote access environment.
  • Read more about the grounds for transfer and personal data transfers on the website of the Data Protection Ombudsman (tietosuoja.fi). If necessary, contact your organization’s data protection officer.

9 Data utilisation plan

• A data controller, as defined by the GDPR, is an organization or individual responsible for determining the purposes and means of processing personal data. This entity is identified based on the data permit decision.
• The data permit can be applied for by the data controller or by another entity on behalf of the data controller.
  • If an entity applies on behalf of the data controller as a data processor, a written data processing agreement must be established between the data processor and the data controller, as required by the GDPR.
• Data controllers:
  • Identify all data controllers.
  • If there are more than one data controller (joint controllership), they must determine the purposes and means of processing the data.
    • Select ‘A Third party‘ and list all data controllers in the additional information field.
• Data processors:
  • List all individuals who will process the data, including their representing organization.
  • Separate the individuals with a semicolon: “Person 1, organization; Person 2, organization; etc.”
• Data minimization principle:
  • Briefly describe how the data minimization principle under the GDPR has been considered.
  • Personal data must be adequate, relevant, and limited to what is necessary concerning the purposes for which they are processed.
• Information obligations to data subjects:
  • Explain how the information obligations towards the data subjects (the target group) have been fulfilled.
  • Attach the privacy notice or equivalent document used for information purposes.
  • If the privacy notice is available online, provide the web address.
• Data Protection Impact Assessment (DPIA):
  • If the GDPR or the Data Protection Act requires a DPIA, attach it to the application.
  • Refer to the Data Protection Ombudsman’s guidelines (tietosuoja.fi) for assistance in conducting a DPIA.
• Research permit and ethical statement:
  • Attach the research permit and/or a favorable ethical statement to the application if necessary.
• Legal basis for processing:
  • State the legal basis for processing personal data concerning the data obtained from Findata and any other data.
  • Note that nearly all data under Findata’s permit authority are special categories of personal data. The processing of such data requires a legal basis under the GDPR.
  • Refer to the Data Protection Ombudsman’s guidelines (tietosuoja.fi) for more information.

10 Additional information and attachments

• List all sources of funding under the question regarding project funding. The sources of funding influence the decision on the data permit fee.
  • A lower data permit fee applies if:
    • The applicant’s place of operation is in Finland or another EU/EEA country.
    • The research is research-driven and funded without external funding or with funding from a public healthcare unit, university, research institution, or other public or non-profit entity.
• Specify any details from previous sections of the application, such as invoicing or the desired processing environment.
• If you have discussed the application with a Findata employee in advance, provide the employee’s first and last name.
• Include all relevant attachments that do not have a designated place on the application form. Do not attach data to the application.

11 Confirmation of information

• Confirm the information provided on the application form.
• The permit decision will be subject to a fee according to the current fee decree. See the current pricing.
• The final costs also depend on:
  • The data controllers’ expenses for extracting data
  • The time Findata spends processing the material.
• Before we make a decision on an application, you must approve the maximum cost estimate for the extraction and pre-processing of data.

See also:

After a data permit has been issued, the data is extracted by different controllers and sent securely to Findata, primarily in CSV format. At Findata, we pre-process and if necessary, combine and anonymise the data.

In practice, we remove all direct identifiers from the data and produce a pseudo ID that allows different individuals to be identified uniquely and information on each individual to be combined from various data sets. The combination of data is applied based on a personal identity code and is only implemented when it does not require for example the harmonisation of classifications.

After the data has been processed, it is transferred to a secure processing environment where the customer can access and process it. The data is delivered in CSV format, with a semicolon as the separator and UTF-8 encoding.

See also:

The costs for data permits consist of the following:

• Decision fee: Charged according to the pricelist.
• Hourly fee: For data processing carried out at Findata.
• Data controller costs: Costs for the extraction and delivery of data, based on each controller’s provisions.
• Kapseli fee: For data forwarded for analysis to Findata’s Kapseli environment.

For more details, visit:

• Pricing
• Kapseli
• Average Cost Estimates (in Finnish)

Data permit pricing

Price category	Criteria	Price
Data permit for a thesis	A data permit related to a thesis for an applicant who is domiciled in Finland or another EU or EEA country. If the project produces several theses or other outputs not related to the thesis, another permit fee category will be applied.	€250.00
Limited data permit	The processing of the application takes less than 7 hours and the applicant’s place of business is an EU or EEA country. For example, new research questions without changes to the data or new extractions.	€300.00
Normal data permit	The application concerns the data of 1 to 15 data controllers and the applicant is established in an EU or EEA country. If the extraction description is modified at the initiative of the applicant in the middle of the application processing process after receiving the cost estimates, or the processing takes more than 14 hours for some other reason, this is an extensive data permit, cf. below.	€1,400.00
Normal data permit for researcher-driven research	Data permit for the applicant whose place of operation is in Finland or another EU or EEA country, with a processing time of 7 hours or more but less than 14 hours, and it is research that is conducted without external funding or with funding from a public health care unit, university, research institute or other public or non-profit association. The application must be accompanied by an explanation of how the research will be funded.	€700.00
Extensive data permit	You may need an extensive data permit e.g. if one or more of the following is met: – The application concerns the data of more than 15 data controllers – The extraction description is modified at the initiative of the applicant after receiving the cost estimates, ie more than one round of cost estimates is required from one or more controllers	€2,000.00
Extensive data permit for researcher-driven research	Data permit for the applicant whose place of operation is in Finland or another EU or EEA country, with a processing time of 14 hours or more, and it is research that is conducted without external funding or with funding from a public health care unit, university, research institute or other public or non-profit association. The application must be accompanied by an explanation of how the research will be funded.	€1,000.00
Data permit for outside the EU or EEA area	Data permit for the applicant whose place of business is in a country outside the EU or EEA.	€3,000.00

Findata’s hourly based fees

Price category	Criteria	Price
Data processing	Hourly fee for data combining, pre-processing, pseudonymisation and anonymisation. Minimum one hour.	€147.00/hour
Data transferring	The price is based on the number of zip folders to be transferred: Base fee: 2 hours × €147 = €294 Additional fee: 0.5 hours (€73.50) per zip folder Example: If there are three zip folders to be transferred, the total cost is: €294 + (3 × €73.50) = €514.50 Each zip folder can be a maximum of 4 GB in size. If the total data to be transferred exceeds 40 GB, we kindly ask that you contact us in advance at data@findata.fi so we can arrange the best approach for transferring your data.	€73.50 per zip folder