Processing of personal data in video conferencing services

1. Data controller

Finnish Customs

Street address: Pasilan virastokeskus (Pasila Office Centre), Opastinsilta 12, 00520 Helsinki

Postal address: P.O. Box 512, FI-00101 Helsinki

Email: kirjaamo@tulli.fi 

Name and contact details of the controller’s contact person:
The Teams service: Marianne Vuolli
Valtori’s video conferencing service: Mika Parkkonen

Email: kirjaamo@tulli.fi

Name and contact details of the data protection officer: Anne Mäkisalo

Email address: tietosuoja@tulli.fi

2. Purpose of processing personal data

Finnish Customs uses Microsoft’s Teams service and Valtori’s video conferencing service to arrange meetings and communication pertaining to the activities and services of Finnish Customs.

3. Basis for processing personal data

The processing of personal data in the Teams service and Valtori's video conferencing service is based on Finnish Customs performing a task carried out in the public interest (Article 6(1)(e) of the General Data Protection Regulation (EU 2016/679)).

4. Registered persons

All persons using the Teams service and Valtori’s video conferencing service are registered.

5. Personal data to be processed

Finnish Customs collects the following personal data about the users of the Teams service and Valtori’s video conferencing service:

  • Name
  • Email address

Customs may also process the following personal data about the users: 

  • Photograph, if the user has uploaded a profile picture in the service.
  • Video footage, if the user has their camera on during the meeting.
  • Audio, if the user has their microphone on during the meeting.
  • Other personal information that the user has entered into the service, for example in a chat window.

The personnel of Finnish Customs is informed about the processing of personal data in the Teams service and Valtori's video conferencing service through a personnel privacy statement published on the Finnish Customs intranet.

6. Sources of personal data

Personal data is collected from external users themselves.

7. Disclosure of personal data

Data is not disclosed routinely, but only in special cases.

The Teams service is part of Microsoft's cloud service suite, so Microsoft or its subcontractors may have access to personal data.

8. Transfers of personal data to third countries

As a rule, Customs does not transfer data outside the EU or EEA. However, the Teams service is part of Microsoft's cloud service suite, where data may be transferred to third countries. In such cases, the basis for the transfer is an adequacy decision of the European Commission in accordance with Article 45(1) of the General Data Protection Regulation.

9. Time limits for storage and deletion of personal data

The Teams service: Information about participants in a meeting is stored until the user or the administrator at Finnish Customs deletes it.

Valtori’s video conferencing service: If the video conference is not recorded, the data is deleted after the end of the meeting. If the video conference is recorded (e.g. for training), the recording and the data are stored in the system for three months.

Chat messages outside the meetings are stored for six months. Shared files saved in the system are stored for seven days.

Log details are stored in the service for two years.