EU General Data Protection Regulation 2016/679
Prepared on: 7 October 2025
Controller
Valteri School
PO BOX 101
40049 VALTERI
Contact persons responsible for register matters
Person responsible
Jaakko Viitasaari, principal
PO BOX 106, 90049 VALTERI
Tel. +358 295 29 4356, firstname.lastname@valteri.fi
Contact person:
Anu Holappa
PO BOX 106, 90049 VALTERI
Tel. +358 295 29 4156, firstname.lastname@valteri.fi
Data protection officer:
tietosuoja@valteri.fi
Name of the register
toimintakykyarvio.fi
Purpose of processing personal data
The service allows functional capacity assessment questionnaires to be sent by email to the student, guardian, and professionals involved in the student’s daily life. The service compiles the responses into different views that can be accessed by the party that sent the questionnaires. The functional capacity data obtained from the service is used to support the student’s learning and school attendance.
Logging into the functional capacity assessment requires registration and an email-based username. The assessments are visible only to a specific user account, and no other persons have access to them.
The data in the register may be used for research and statistical purposes. For research use, the researcher must apply separately for a research permit from Valteri.
Research data must be minimized, and research should be carried out without personal data whenever possible. If the research cannot be conducted without personal data, a data protection impact assessment must be carried out.
Data content of the register
Name (optional), email address
The use of the system does not require the use of the student’s name or identifying information and promotes anonymity. The party administering the functional capacity assessment sends the questionnaires by email through the service, but the recipients’ email addresses are not stored on the server. The system compiles the responses for reporting to the administrator.
Sources of personal data
Personal data is collected only from registered users.
Non-disclosure and disclosure of evaluation information
The documents that can be printed out and downloaded from the service are non-disclosable, and the information contained therein may only be accessed by the teachers teaching the student concerned and other persons who need the information for their work. They may access the information to the extent that they need it for their work.
Section 23 of the Act on Compulsory Education states the following about the transfer of information: “An education provider responsible for the guidance and supervision of a student in compulsory education within the meaning of sections 11 and 12 and a municipality within the meaning of section 14 of this Act shall have the right, notwithstanding non-disclosure provisions, to obtain from another education provider or municipality the information necessary for the performance of their duties under this Act concerning the application procedure for, obtaining and acceptance of a place of study by the student, the commencement and discontinuation of the student’s studies and the suspension of the student’s compulsory education.
Notwithstanding non-disclosure provisions, an education provider shall have the right to obtain from another education provider or from the municipality responsible for guidance and supervision the information on a student’s compulsory education, previous studies and any suspension of such studies that is necessary for the performance of its duties related to the free education referred to in this Act.
When a student in compulsory education transfers to education provided by another education provider, the previous education provider must, notwithstanding non-disclosure provisions, immediately provide the new education provider with the information necessary for organising the student’s education. When a notification concerning a student in compulsory education referred to in section 11, subsection 4 or section 13, subsection 1 is made to the municipality of residence, the education provider must, notwithstanding non-disclosure provisions, provide the municipality of residence with the information necessary for the implementation of the responsibility for guidance and supervision provided for in section 14 and for the assignment of a place of study. This information must also be provided at the request of the new education provider or municipality of residence. (8.7.2022/715)
In addition to the provisions of subsection 3, a principal and a teacher involved in the instruction of a student in compulsory education shall, in the education referred to in section 4, have the right, notwithstanding non-disclosure provisions, to obtain from those involved in student welfare work the information necessary for organising the student’s education. The party responsible for the guidance and supervision of a student in compulsory education in the municipality of residence of the student shall have the right, notwithstanding non-disclosure provisions, to obtain from those involved in student welfare work the information necessary for the implementation of the responsibility for guidance and supervision provided for in section 14 and for the assignment of a place of study. (8.7.2022/715)
The provider of primary and lower secondary education must provide the new education provider with a decision on support valid at the end of primary and lower secondary education in accordance with section 20 f of the Basic Education Act in the situations referred to in section 67, subsection 3 of the Act on Vocational Education and Training, section 22, subsection 1 of the Act on Preparatory Education for Education and Training to Complete a Qualification and section 28 b, subsection 2 of the Act on General Upper Secondary Education. The decision must also be provided at the request of the education provider. (30.12.2024/1091)
Subsection 5 amended by Act 1091/2024 shall enter into force on 1 August 2026. The previous wording is:
The provider of primary and lower secondary education must provide the new education provider with a decision on special support valid at the end of primary and lower secondary education in accordance with section 17 of the Basic Education Act in the situations referred to in section 67, subsection 3 of the Act on Vocational Education and Training, section 22, subsection 1 of the Act on Preparatory Education for Education and Training to Complete a Qualification and section 28 b, subsection 2 of the Act on General Upper Secondary Education. The decision must also be provided at the request of the education provider. (19.12.2024/804)”
Non-disclosable information may be disclosed more widely with the consent of the student’s guardian. With the consent of the student and their guardian, documents containing information on the student’s functioning obtained from the service may be transferred to a receiving educational institution at the start of studies in order to enable adequate support measures after primary and lower secondary education. The information must be handled confidentially.
The information may not be disclosed or transferred outside the EU or the EEA.
Principles of Register Protection
The data stored in the register is kept in digital form on the system server’s hard drive. The servers are located in a locked and monitored facility. The register is password-protected, and access rights are defined and restricted to certain individuals based on their job responsibilities. The party responsible for administering the functional capacity assessment ensures that the compiled description of functional capacity is recorded and stored in accordance with the educational institution’s documentation practices.
Rights of the Data Subject
According to the EU General Data Protection Regulation (EU) 2016/679, a person whose data is processed (the data subject) has various rights depending on the legal basis for processing personal data.
The individual has the right to know (right of access, Article 15) whether their personal data is being processed and what personal data concerning them is stored.
The individual also has the right to request the correction of inaccurate personal data.
The data contained in the register is mainly confidential. Data is not disclosed unless the requesting party has a legal right to obtain the information. Therefore, the data subject does not need to submit a specific request to prohibit disclosure.
The individual has the right, only in certain exceptional cases, to have their personal data completely erased from the registers (right to erasure, Article 17).
Data subject rights are exercised by first contacting the contact person of the data controller responsible for the register, whose contact details are provided at the beginning of this document.
If you believe that we are violating applicable data protection legislation in the processing of personal data, you have the right to lodge a complaint with the national data protection authority
