Archiving client and patient data after operations cease

Archiving client and patient data after operations cease

When a private health care and social welfare services provider ceases operations, it must submit the client and patient documents of its customer register to Kela for storage. Kela's patient and client document archiving service accepts paper and electronic material that has not been stored in Kanta. The data is transferred for joint control by Kela and the wellbeing services counties or the City of Helsinki.

The cessation of operations means the termination of professional activities in the field of social welfare and health care due to

  • winding down business operations
  • a change of career 
  • or retirement. 

The cessation of operations must be reported to the regulatory authority. If the service provider has stored data in Kanta, the customer relationship with the Kanta Services must be terminated.

Archiving documents at Kela

The Client Data Act, which will enter into force on 1 January 2024, obliges service providers that are ceasing operations to submit the electronic and paper patient and client documents that they control to Kela for storage. The obligation also applies to service providers that ceased operations prior to 2024.

However, the materials will not be submitted to Kela if the patient and client documents

  • have previously been submitted to the wellbeing services county or the City of Helsinki
  • have previously been saved in the Kanta Services
  • are contractually available for archiving, for example, to another company.
    • If a private health care and social welfare services provider agreed on the joint control of data with another private service provider during its operations, it can be agreed that the other joint controller shall control the documents belonging to the party ceasing operations.

Kela's patient and client document archiving service

Kela's archiving service is intended for private social welfare and health care service providers whose operations have ceased completely. It accepts 

  • paper and electronic patient and client documents, including image material, from private social welfare and health care service providers
  • occupational health care patient and client documents, if the employer has arranged occupational health care services for its own personnel and stopped providing the service 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.

Archiving in Kanta

A service provider ceasing operations may submit patient data to Kanta's Old Patient Data Repository before its operations cease. A prerequisite for this is that the data must be converted into a format that meets the requirements for storage. Patient data can be archived according to the requirements for archiving old data.

The service provider ceasing operations is responsible for

  • extracting data from the source system
  • converting the material into a format that meets requirements
  • submitting material to Kanta
  • any costs incurred in the process.

The data stored in the Patient Data Repository will remain visible to citizens in MyKanta even after the operations have ceased, and they can still be disclosed from the Patient Data Repository to other service providers.

Patient data stored in the archive as old patient data is not visible in MyKanta and cannot be disclosed to other service providers.

Old social welfare client data

Old social welfare client data is stored in the Client Data Repository for Social Welfare Services in accordance with the requirements for old client data. Documents saved as old client data are not visible to citizens in MyKanta. Old client data will not be disclosed to other service providers. An exception to this is social welfare authorities, if they search for client data from Kanta under the authorities' extensive right of access.

Old image material

Old image material cannot be archived in the Kanta services. If a service provider that has ceased operations has image material that has not been archived in Kanta, the service provider can submit the material to Kela's archiving service.

Controller of documents after operations cease

Once a service provider has ended its operations, the documents submitted by the service provider to Kela are transferred for joint control. The joint controllers of the data are Kela and the wellbeing services county in whose area the service provider's domicile is located, 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

When operations cease, the controller must inform the data subjects of

  • the cessation of operations
  • the effects of the cessation of operations on the processing of data in the data file.

In practice, informing may mean, for example, contacting data subjects or posting information on the matter on the controller's website. The retention periods of patient documents are determined in accordance with the appendix to the Client Data Act.

Read more

Patient and client document archiving service (kela.fi, in Finnish and in Swedish)

Last updated 11.6.2024