The operation of a private health and social services provider may end, for example, due to the winding down of business operations, a change of career or retirement.
The service provider must remember to
- notify Kela’s archiving service for patient and client documents of the change by email: toimintansa.lopettaneet@kela.fi
- notify the supervisory authority of the cessation of the operations (lvv.fi, in Finnish)(opens new window)
- terminate the client relationship with the Kanta Services if it has stored data in Kanta.
Archiving documents at Kela
The Act on the Electronic Processing of Client Data in Healthcare and Social Welfare (Client Data Act) obliges the service provider ceasing operations to submit the electronic and paper patient and client documents that it controls to Kela for storage. This also applies to service providers that ceased operations before 2024, when the Act entered into force.
However, the data will not be submitted to Kela if the patient and client documents
- have previously been stored in the Kanta Services
- have previously been submitted to the wellbeing services county or the City of Helsinki
- are contractually archived by another company, for example, in situations where several private service providers have joint control of the data.
Kela's patient and client document archiving service
Kela’s archiving service accepts
- paper and electronic patient and client documents, including imaging data, from private providers of health and social services.
- patient and client documents from occupational health care if the employer has arranged occupational healthcare services for its own personnel and stopped providing the services itself.
Archiving materials at Kela is free of charge. However, the service provider or its representative shall bear the costs incurred from
- organising and storing the material in the format required by Kela
- transferring the material to Kela.
Saving electronic documents in Kanta Services
It may be possible for a service enabler ceasing operations to submit client and patient data to Kanta as old data.
In this case, the service provider is responsible for
- retrieving the data from the source system
- converting the data into a form meeting the requirements
- submitting the data to Kanta
- the costs arising from these.
Patient data can be stored in Kanta according to the requirements for old data.
Patient data stored as old data in the Patient Data Repository are not visible in MyKanta and cannot be disclosed to other service enablers. An exception to this is searches related to the extensive rights of access to information from Kanta, in which case old patient data can also be disclosed.
Read more:
Old imaging data cannot be archived in the Kanta Services. If the service provider that has ceased operations has imaging data that have not been stored in the Imaging Data Repository, the service provider shall deliver them to Kela’s archiving service.
The old client data from social welfare will be stored in the Client Data Repository for Social Welfare Services in accordance with the requirements for old client data.
Documents stored as old client data in the Client Data Repository for Social Welfare Services are not visible to citizens in MyKanta. As a rule, old client data are not disclosed to other service providers. An exception to this are the social welfare authorities if they search for customer data in Kanta under the authorities’ extensive right of access to information.
Read more:
Who is the controller of the documents after the cessation of operations?
Once the service enabler has ceased operations, the documents it has submitted to Kela and during its operations stored in the Kanta Services will be transferred for joint control. The joint controllers are Kela and the wellbeing services county in whose area the service enabler’s operations were registered or the City of Helsinki.
Kela is responsible for
- responding to citizens' requests for information and forwarding the request for information to be fulfilled
- the secure storage and destruction of documents.
The wellbeing services counties, the City of Helsinki, or another agreed service provider is responsible for other controller obligations under the General Data Protection Regulation, such a
- rectification of data
- disclosure of data upon a request for information.
Kela's archiving service and Kanta services cannot make corrections to documents.
The controller’s responsibilities have been described as follows:
- with regard to change situations and the cessation of operations, in the guide on the processing of client data in health and social services (yhteistyotilat.fi)
- with regard to the storage periods of patient documents, in the annex on storage periods in the Client Data Act (finlex.fi, in Finnish)(opens new window)
- rwith regard to the control of the data, the EU's General Data Protection Regulation (europa.eu)(opens new window).
Notify clients of the cessation of operations
At the end of operations, the service enabler must inform its clients of
- the cessation of its operations
- which operator will in the future be responsible for the data stored in the register and make any corrections to the data.
In practice, informing may mean contacting clients or reporting the matter on the website, for example.
Please note that the data stored in Kanta during the operation is still visible to the citizen in MyKanta even after the operations have ceased and can be further disclosed from the Patient Data Repository or the Client Data Repository for Social Welfare Services to other service enablers.