FINENTRY Terms of Service (June 1st, 2021/updated)
1 Application of Terms of Service
The use of FINENTRY service (hereinafter “Service”) produced by the Hospital District of Helsinki and Uusimaa (hereinafter “HUS”) requires that the authenticated or registered user (hereinafter “User”) accepts and adheres to these terms of service. The User needs to read through these terms of service carefully before starting to use the Service.
2 Registration and Approval of Terms of Service
The User accepts these terms of service upon authentication or registration on the Service. Anyone may register on the Service. The Service is personal, although the User may also book a test appointment for their family members through the Service.
User who has a Finnish social security number
When the User books a coronavirus test appointment on the Service, the User needs to authenticate themselves on the service using personal electronic banking credentials or mobile ID. The Service also allows acting on someone’s behalf, in which case the person who has the credentials to act on the User’s behalf authenticates themselves on the service using personal electronic banking credentials or mobile ID, and then acts on the User’s behalf. In case of acting on someone’s behalf, the personal data of both parties will be stored in the database of the Service.
If the User is unable to undergo strong authentication, they will register on the Service in the same manner as a user who does not have a Finnish social security number.
User who does not have a Finnish social security number
When the User books a coronavirus test appointment on the Service, the User needs to register on the service using full name and personal information. During registration, the User will be provided a temporary social security number, which will remain the same for each login. The temporary social security number and personal information provided during registration will be stored in the database of the Service. The registration is then verified with a single-use authentication code sent to the User’s phone number via text message. The User sets their personal password upon registration. After registration, the User may log into the Service via this password. The User is also sent a new single-use authentication code via text message upon each login. The password used to log into the Service is personal.
The User needs to store their password and temporary social security number created by the Service carefully. The User must not disclose their user information or password to any external parties, unless the person in question has a right to log into the Service on the User’s behalf in accordance with these terms of service. The User has an exclusive responsibility for the appropriate use of the user account on the Service. The User must immediately report to the organization responsible for administrating user information (HUS) in case the User loses their user information required to log into the Service.
User who has a professional acting on their behalf to book an appointment or create a sample request
If the User, for one reason or another, is unable to use the FINENTRY service by themselves, a professional working at the health information point of a border crossing point can fill in the User’s information on their behalf through a professional’s interface and create a sample request and/or a temporary social security number, or book an appointment on the User’s behalf for coronavirus testing after 72 hours has passed at a sampling point outside the border crossing point, e.g. municipality of stay.
When the professional fills in the User’s information on their behalf in the FINENTRY service, the professional will inform the User regarding the purpose of the information. The User accepts the use and storage of information by continuing to provide the professional with personal information after learning the mentioned purpose.
3 Right to Use the Service
Only those users who are registered on the Service have the right to use the user account in the Service. The Service is only intended for people over the age of 16.
Using the Service is free of charge. If the User books a coronavirus test appointment at one of the sampling points assigned by the Service, sample collection, analysis and test results will all be free of charge for the User.
The User always has an exclusive responsibility for the appropriate use of the Service in accordance with the terms of service. The User must report to HUS immediately in case the User suspects that the Service is being used on their behalf without authorization or any other order, or otherwise against these terms of service.
4 Purpose of the Service and Its Use
The Service is intended to inform and instruct the User, as well as let the User book a coronavirus test appointment insofar as it is possible within the Service at any given time. The Service contains useful information regarding the COVID-19 epidemic that is targeted to the User, as well as instructions by the Finnish authority and information regarding regional sampling services connected to the Service.
Coronavirus tests booked through the Service will not provide a separate coronavirus test certificate.
HUS has an exclusive right to decide the scope and contents of the Service provided to the User. The Service allows the User to determine the most appropriate instructions for their own circumstances when entering Finland, as well as plan for schedules to coronavirus testing upon entry and book a test appointment at the immediate vicinity of the point of entry and/or in their current municipality of stay in Finland. The Service will send the following to the User’s phone number via text message: a confirmation message and arrival instructions for testing, a notification regarding the test appointment and the test results approximately within 24 hours from testing.
The Service is not intended to replace a medical diagnosis or health assessment carried out by a healthcare professional. The User has an exclusive responsibility for their health when using the Service. The User is expected to base any decisions related to their health on their own judgment. The User must always contact a doctor to receive a health assessment, healthcare or preventive help for a disease, injury or any other discomfort.
When using the Service, the User will be informed about the practices under the Finnish Communicable Diseases Act (1227/2016), in case the results of the User’s coronavirus test turn out positive. If the User receives a positive laboratory test result for the coronavirus, the User’s data is transferred to a separate register of the communicable disease authority operating at the User’s municipality of stay for tracking purposes under the Finnish Communicable Diseases Act (1227/2016). The data is not automatically transferred to any other registers, such as the patient register of hospital districts or municipalities, or any third-party registers. However, it is noteworthy that FINENTRY service’s own personal information register is logically divided into two registers: patient register based on patient care (testing and booking related to these tests) and case-by-case register based on tracking the infections. The information in these two registers is connected and can be transferred from one to another through administrated views, for example between the party responsible for testing and the communicable disease authority at a municipality of stay.
The User is responsible for the correctness of any information provided and entered to the Service and commits to report to HUS immediately in case of finding any shortcomings or flaws in the information.
The User warrants and is responsible for not sending any illegal or otherwise inappropriate content within the Service. The User needs to ensure by all reasonable means that the material sent does not contain viruses and is otherwise not harmful.
5 Contents of the Service and Third-Party Services
The Service may be used to share information from third-party services or links to third party services. The Service is used to share appropriate information regarding the pandemic and guide people to the websites of Finnish authorities. HUS is not responsible for any contents on the third-party services but aims to ensure correctness of all information.
When the User books a coronavirus test appointment, the Service transfers the User’s social security number or temporary social security number, name and phone number to the healthcare professional who operates at a sampling point and works in the unit of HUS or other regional hospital district, or in the unit of a contractual subcontractor.
The User may use third-party services through the links on the Service or otherwise through the Service, but in such cases, HUS is not a contracting party or otherwise responsible for any information and its implementation transferred or provided by the User or the third party.
6 Use of Personal and Other Information
The service stores sensitive information of the User. Such information includes: social security number or temporary social security number, full name and phone number, country of origin, border crossing point, date and time of arrival, means of transport and an identifier related to it (e.g. flight number), municipality and address of stay, potential municipality of residence and home address, whether the User has any coronavirus-related symptoms, whether the User has been in close contact with a person who has a laboratory-confirmed coronavirus infection, whether the User has a negative coronavirus test certificate in the country of origin, and whether the User has a certificate indicating a recovery from the disease. In case someone is acting on the User’s behalf, the service stores that person’s name and municipality of stay. The User may enter any information they wish to the Service insofar as the Service enables it and as is required for booking a coronavirus test appointment on the Service. The User is responsible for the correctness of all information entered on the Service.
The information on the Service is visible only to the User and, to a limited extent, the healthcare staff at each coronavirus sampling point, and the professional operating at the Communicable Disease Unit in the User’s municipality of stay if the User’s coronavirus test result turns out positive.
FINENTRY service processes user information with two different purposes:
- Patient care (patient register)
Testing is mainly for the purpose of patient care, and the information required for testing (including appointment information) is patient information. The information is part of the patient register controlled by the health care unit taking care of the patient.
The patient register is controlled by the healthcare unit that carries out the testing. The controller is not necessarily the same between tests carried out in the municipality of arrival and municipality of stay.
- Infection tracking (case-by-case register)
Infection tracking is based on the Communicable Diseases Act, in which Section 39 allows collecting and processing the information of people who have been infected or are suspected of an infection. The information is part of the case-by-case register of the hospital district responsible for infection tracking.
The case-by-case register is controlled by the hospital district where the entrant’s municipality of arrival is located or where the entrant stays at some point.
The information in the case-by-case register is transferred from one hospital district to another automatically based on the entrant’s movement between municipalities.
The hospital district ensures that the information within its region is transferred sufficiently to municipalities in case they are performing independent infection tracking.
HUS is the processor of user information on the FINENTRY service, other than the information in its registers.
Third-party services and websites have their respective data protection principles regarding personal information. HUS is not responsible for the operation of third-party websites or services.
7 Intellectual Property Rights of the Service
HUS or the third party have the intellectual property rights on all the content within the Service, its layout, and all the materials available on the Service. The User may print or save any material available on the Service for private use. If any material on the Service is used in accordance with the Copyright Act (404/1961), the source needs to be always mentioned. The trademarks contained within the Service may not be reproduced, published or further disseminated without a written consent by HUS.
8 Limitations of Liability
HUS provides its Service under the principles of “as is” and “as is available”. HUS does not guarantee that the Service can be used without interruption or error. HUS cannot guarantee the availability or flawlessness of the Service. HUS is not responsible to the User or third parties for the contents of the information presented on the Service, their correctness and any potential flaws, shortcomings or delays with the information. The User is responsible for having a functional network connection and sufficient technical qualifications and software to use the Service properly. The User is also responsible for the safety and functionality of the devices and software they use.
The Service is not intended to replace a medical diagnosis or health assessment by a healthcare professional, and HUS is not responsible for any actions by the User initiated due to any information presented on the Service, subject to a mandatory provision in the Law.
Liability of HUS extends to mandatory provisions in the Finnish Law. HUS or the User are not responsible for the damage which arises as a result of neglected obligation caused by an unusual or unforeseeable cause that is beyond the party’s control.
HUS may report regarding a force majeure on the front page of the Service, on its website and the websites of authorities and hospital districts.
9 Cancellation of Service
The User has the right to cancel a coronavirus test appointment booked through the Service by using a cancellation code sent via text message not later than 3 hours before the appointment. User data in the Service cannot be removed if the User has booked a test appointment, as data retention in the patient register of the municipality where the User stays and uses services is based on the Finnish law (Health Care Act 1326/2010).
HUS has the right to terminate the User’s account on the Service for a justified reason in case the use of Service causes harm to HUS, the User or third parties, or the Service has otherwise been used against these terms of service.
HUS has the right to stop providing services when the authorities have declared that the coronavirus pandemic has ended. When the service will be cancelled, the information of Users will be transferred, insofar as necessary, to a space appointed by each data controller. The amount of transferred information will be minimized as much as possible, and the information will be anonymized insofar as possible under the Finnish Law. Unnecessary information will be deleted. When the service ends, the User’s information will not be available to the User anymore.
10 Applicable Law and Forum
The Finnish Law is applied to these terms of service. Any disputes caused by these terms of service will primarily be resolved through negotiations between the parties. If the dispute cannot be resolved through negotiations, it will be settled by the Helsinki District Court or another district court at the location of the User’s domicile or permanent residence.
11 Cookies and software used on the website
General information regarding cookies used on the service
The user may block cookies in the browser settings. However, using the website without cookies may affect its functionality.
Microsoft Azure App Insights
Microsoft Azure App Insights tool is used for monitoring and reporting errors. If an error occurs in any process on the Service, monitoring data can be used to find out where the error occurred and what may have caused it.