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FINLAND
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DOCUMENTS
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RETENTION PERIOD
(minimum and/or maximum)
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BEGINNING OF RETENTION PERIOD
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LEGAL REFERENCE
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EMPLOYMENT RECORDS
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Contracts
(new hire agreements, severance, etc.)
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Contracts: Minimum 10 years (in case certificate of employment is requested)
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From termination
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Employment Contracts Act (55/2001), Ch. 6, Sec. 7
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Time records (work hours, rest periods, vacation/sick/ holiday, etc.)
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1. Notes and documentation relating to payroll: Minimum 6 years
2. Motor vehicle drivers' personal driver's logs: Minimum 1 year
3. Working hours register: Minimum 2 years
4. Holiday records: Minimum 2 years
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1. From end of fiscal year
2. From date driver's records are submitted to employer
3. Active employee: From end of year record was made;
Terminated employee: From termination
4. Active employee: From end of year record was made;
Terminated employee: From termination
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1. Accounting Act (1336/1997, Ch. 2, Sec. 10)
2 & 3. Working Hours Act (605/1996, Ch. 7 & 8)
4. Annual Holidays Act (162/2005, Ch. 6, Sec. 29 & 34)
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Performance records (reviews, promotions/
demotions, licenses/certs., investigations, disciplinary actions, etc.)
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1. Performance records: Minimum 5 years (in case certificate of employment is requested)
2. Disciplinary/ grievance records: Maximum 10 years
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From termination
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1. Employment Contracts Act (55/2001), Ch. 6, Sec. 7
2. Limitations Act (728/2003), Sec. 7; and,
the Finnish Business Archive Association's non-binding recommendation
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Data and personnel files
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General: Retain as long as necessary for pre-defined purpose(s) of use and necessity requirement is met.
Maximum 2 years if there is no need to retain data for longer period.
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From termination
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Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3;
Employment Contracts Act (55/2001), Ch. 13, Sec. 9;
The Finnish Data Protection Authority's non-binding recommendation
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Government verification records (work papers, immigration, eligibility to work, etc.)
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1. Alien records: Minimum 4 years
2. Contracted work - certificates and records specified in the law: Minimum 2 years
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From termination
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1. Aliens Act (301/2004), Ch. 5, Sec. 86a
2. Act on the Contractor’s Obligations and Liability when Work is Contracted Out (1233/2006), Sec. 5
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Collective bargaining/union
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May be retained permanently, provided does not include personal data
If includes personal data: Maximum as long as necessary for pre-defined purpose
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From end of recording
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Best practice
GDPR art 5(1)(e); Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3
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Background checks and drug tests
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Background checks: Maximum 6 months
Drug tests: Delete immediately when no longer necessary for purpose. Reason and need for processing should be re-evaluated at maximum of five-year intervals. Note: Finnish Data Protection Ombudsman recommends deletion/re-evaluation be carried out at maximum two-year intervals.
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From receiving results of test or check
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Act on Background Checks (726/2014), Ch. 6, Sec. 45;
Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 5 and Ch. 3, Sec. 6;
The Finnish Data Protection Authority's non-binding recommendation on "Työelämän tietosuojan käsikirja", updated June 21, 2018.
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Acknowledgements, policy agreements and required notices
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May be retained permanently, provided there's no personal data;
If includes personal data: Maximum as long as necessary for pre-defined purpose
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From creation
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Best practice
GDPR art 5(1)(e); Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3
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Recruitment (interview notes, resumes/CVs, reference checks, etc.)
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1. Unsuccessful applicants:
Minimum one year based on potential for employee claims (compensation and discrimination). Non-binding recommendation from Finnish Business Archive Association is to retain application forms and interview notes for two years.
2. Successful applicants:
Recommended to retain job application and resume for employment plus 5 years.
If necessary to store longer, retain only as long as necessary for recruitment process.
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1 & 2. From end of recruitment process
If required to provide a certificate on employee's working skills and behavior: From termination of employment
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1. Unsuccessful applicants:
Non-discrimination Act (1325/2014), Ch 5, Sec. 26;
Act on Equality between Women and Men (609/1986), Sec. 12
2. Successful applicants:
Employment contracts Act (55/2001), Ch. 6, Sec. 7
Best practice
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Tracking/recordings (biometric, geo-location, online tracking, camera recordings, etc.)
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1. Camera recordings: Retain only as long as necessary and no longer than 1 year, unless an approved exception, such as unfinished harassment investigation
2. Location data: Retain only as long as necessary for purpose, then delete or anonymize, unless otherwise provided by law
3. Biometric data: Retain only as long as necessary for pre-defined purpose
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From end of recording/collection
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1. Act on the Protection of Privacy in Working Life (759/2004), Ch. 5, Sec. 17
2. Act on Electronic Communications Services, Ch. 20, Sec. 160
3. GDPR art 5(1)(e); Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 3
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List of young workers
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List must be up-to-date and outdated information should be deleted immediately
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From recruitment or from employment
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Young Workers’ Act (998/1993) Ch. 4
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BENEFIT/PENSION/EQUITY RECORDS
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Benefits
(plan documents, enrollment records)
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1. For information part of accounting material/ payroll records: Minimum 10 years
2. Other documents: As long as necessary for purpose
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1. From end of fiscal year
2. From collection
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Accounting Act (1336/1997), Ch. 2, Sec. 10;
Act on taxation procedure on self-assessed taxes (768/2016), Ch. 4, Sec. 28
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Pension and retirement records
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1. Insurance and pension records: Minimum 10 years
2. For information part of accounting material: Minimum 6 years
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1. End of validity of insurance policy
2. From end of fiscal year
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1. & 2. Insurance Contracts Act (543/1994); Employees Pensions Act (395/2006); Limitations Act (728/2003), Sec. 7;
Accounting Act (1336/1997), Ch. 2, Sec. 10
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Equity records
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General: No specific requirements, retain as long as necessary
Accounting related material: Minimum 6 years.
Note: Shareholder records should be retained throughout company's operations
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From end of fiscal year
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Accounting Act (1336/1997), Ch. 2, Sec. 10
Limited Liability Companies Act (624/2006), Ch. 3, Sec. 15
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PAYROLL/WAGE/TAX RECORDS
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Payroll and wage data (payslips, etc.)
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Payroll records: Minimum 10 years
Notes and supplemental documentation relating to payroll: Minimum 6 years
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From end of fiscal year
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Accounting Act 1336/1997 (Ch. 2, Sec. 10);
Employment Contracts Act (55/2001, Ch. 13);
Prepayment Act (1118/1996);
Act on taxation procedure on self-assessed taxes (768/2016), Ch. 4, Sec. 28
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Tax records
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Minimum 10 years
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From end of fiscal year
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Accounting Act (1336/1997, Ch. 2, Sec. 10)
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MEDICAL/SAFETY/LEAVE RECORDS
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Leave (family, medical, etc.)
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1. Notes and supplemental documentation relating to payroll: Minimum 6 years
2. Holiday records: Minimum 2 years
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1. From end of fiscal year
2. Active employee: From end of year record was made;
Terminated employee: From termination
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1. Accounting Act (1336/1997, Ch. 2, Sec. 10);
2. Working Hours Act (605/1996, Ch. 7 & 8);
Annual Holidays Act (162/2005, Sec. 29 & 34)
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Injury and illness incident reports
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Minimum 10 years (based on limitation concerning bodily injury caused to an employee)
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From incident
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Employment Contracts Act (55/2001), Ch. 13, Sec. 9;
Limitations Act (728/2003), Sec. 7
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Medical records
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Only permitted for limited purposes.
Erase immediately when no longer necessary for purpose. Reason/need for processing should be re-evaluated at maximum five-year intervals.
Note: Finnish Data Protection Ombudsman recommends deletion or re-evaluation at maximum two-year intervals.
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From recording
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Act on the Protection of Privacy in Working Life (759/2004), Ch. 2, Sec. 5;
Non-binding recommendation from the Finnish Data Protection Authority found in "Työelämän tietosuojan käsikirja", updated June 21, 2018.
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Hazardous material and other exposure records
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1. List of employees exposed to biological agents: Minimum 40 or 10 years depending on agent
2. List of employees exposed to carcinogens (the ASA Register): Minimum 80 years
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From end of exposure
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1. Occupational Safety and Health Act (738/2002), Ch. 5, Sec. 40a
2. Act on Respecting a Registry of Employees Exposed in Their Work to Carcinogenic Agents and Substances (717/2001), Sec. 5
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