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Finland and biometric data

Developments to keep an eye on – Finland and the proposal to amend the regulation on biometric data

The Finnish Ministry of the Interior is working on changing the regulations concerning biometric data. Currently, in Finland biometric data is collected when a person applies for a passport or an identity card – the two officially recognized forms of identification. Biometric passports have been in use from 2009; and since 2021 getting an identity card also requires biometric data. Thus, it’s no longer possible to acquire an official form of ID without submitting one’s biometric data to the state registries.

Biometric data of Finnish citizens – facial images and fingerprints – for passports and identity cards is stored in the respective registers of the Finnish police, whilst the biometric data of foreign nationals is stored in the registers of the police and the Finnish Immigration Service.

The proposed amendment to the regulation on biometric data stored in these registries would extend the right of the police to use this data. These possibilities were already discussed in public when the initial regulation on biometric data was formulated. At the time it was strongly emphasized that biometric data will not be used for any other purpose as it is sensitive personal data. However, the police have been pushing for the now proposed amendments since 2009.

The argument used by the current administration proposing the changes is that opening the registries would help to combat serious crimes. Additionally, the claim is that biometric data would only be used for this particular purpose. As the press release by the Ministry of Interior states: “The proposed amendments would extend the right of the police to use biometric data already in their possession. It would not extend the right of the police to collect data. For example, the police could compare biometric data in its registers to data collected as part of investigations into serious crime, such as homicides and serious violent and sexual offences.” 

The main problem is, as journalist Susanna Reinboth who specializes in legal matters, points out: “the founding principle is that personal data can be used only for the purpose it has been collected for”. Making an exception to this founding principle in this instance would seriously erode it, and further changes will be easier to make. Moreover, biometric data is not just any kind of personal data, but extremely sensitive personal data. Thus, it should be stored and used with even more care. 

Further concerns were raised by academics Aura Kostiainen and Liisa A. Mäkinen: that the biometric data could more easily be given over to other EU countries, such as authoritarian Hungary, and that there is no outside oversight of the police in this matter included in the proposal. The only oversight would come from the National Bureau of Investigation, so in practice the police is overseeing itself, instead of the justice system or democratic oversight. In recent years, there have been cases illuminating how the internal oversight has crucially failed in very serious instances.

The proposed amendments are a matter of basic civic rights and freedoms, and that’s why any concerned individual should be paying attention to these developments. Yet, the proposal has gotten very little attention in public discussion.

A few articles were published in the main daily Helsingin Sanomat in February 2025 when the Ministry of Interior announced the proposal, including an open call for comments (closed mid March). 26 comments were submitted by various officials and civil society actors. These are publicly available on the Ministry of Interior website (in Finnish, see the legislation process link below). The comments include criticism to the unclear framing and wording of the changes which would constitute future problems for the execution of the regulation and criticism to the lack of impact assessment especially regarding the impact on children. (Side note: Lack of impact assessment has been a major criticism of a considerable amount of new legislation in recent years.)

The parliamentary procedures regarding the proposed amendments are likely to begin in week 37 (second week of September). So now is a good time to contact members of the parliament, if one wishes to voice concerns about the proposal.

Sources and further reading:

Intermin press release: https://intermin.fi/-/ehdotus-biometristen-tietojen-kayttoa-rikostorjunnassa-koskevan-saantelyn-muuttamisesta-lausuntokierrokselle?languageId=en_US

In Finnish:

Susanna Reinboth column: https://www.hs.fi/mielipide/art-2000011017812.html

Aura Kostiainen and Liisa A. Mäkinen comment: https://www.hs.fi/paakirjoitukset/art-2000011234592.html

Legislation process https://intermin.fi/hankkeet/hankesivu?tunnus=SM048:00/2023

Articles: https://www.hs.fi/politiikka/art-2000011010281.html

https://www.hs.fi/suomi/art-2000011009647.html

https://www.uusijuttu.fi/juttu/sB26nfj2-mpinP64c-b210f

 

The UNDO team.

Workshops in Finland - Call for participants

 

workshop image

Understanding and responding to surveillance in Finland

How do the Finnish authorities surveil activists, and how can activists and researchers work with that? The topic of this workshop is to understand surveillance as well as the rights and strategies connected to it. It is organized by the project "Understanding Nordic Digital Order: Digitalisation of Policing in the Nordics, Activism, and Surveillance Oversight" (UNDO) funded by the Kone foundation. UNDO works on facilitating democratic oversight and control over digital policing. We develop legal and political strategies, awareness, and build technological tools for furthering citizen control over surveillance and digital policing. 

UNDO tries to critically identify what is going on in the Nordics (SWE, DEN, FIN), with the digitalization of police forces in general and urban surveillance in particular. By discussing with activists and political movements in the aforementioned countries UNDO aims to identify what areas of the surveillance infrastructure need to become visible, how political action is affected by it and think about ways to counteract. Furthermore, UNDO wants to examine potential ways of bottom-up resistance to excessive digital policing strategies, the new surveillance shift which is taking place in the Nordic countries.

The UNDO project will design and develop software solutions that will try to help political activism, making the surveillance infrastructure visible, and keeping those in power accountable.

UNDO is a combination of research, activism and art. This way the project will try to expand its reach beyond traditional academic routes and will work towards the popularisation of its findings. This means further visibility and connectivity between interested parties (other activists, social movements) throughout Europe.

We are inviting you to participate in a workshop in Helsinki.

The conversation in the workshop will revolve around the description of this territory of surveillance and its exposure. What are the old and new systems deployed by the police? Who do these systems target exactly? Can these systems be circumvented? Can we think of possible software to help bypass or disclose this network? Is an algorithm for determining police violence or the next police raid feasible? Is a probabilistic mapping scenario of the expansion of the police surveillance network beneficial for targeted political interventions?

Having these questions in mind, we want to explore ways of counter-engineering software systems and try to see how such systems can be used for emancipatory purposes.

We will have two workshop sessions, you may choose the one that is most suitable for you timewise. The sessions take place in Koneen säätiön Kamari  (Tehtaankatu 21 B 45, 5th floor)

on

Friday February 21st at 16-18 

and

Saturday February 22nd at 12-14 

We will offer some snacks and beverages.

Documentary

Part of the project is a documentary to get visibility for the issues UNDO researches. The film will look at these issues and how they affect social movements in the Nordic countries. The rough plan is to follow the climate movement in Finland, the palestinian solidarity movement in Sweden and the housing justice movement in Denmark. Members of the film collective RåFILM (they have also filmed with XR in Sweden) are making the documentary. 

We are looking for a couple of people connected to XR that can talk on camera about their experiences in the movement and reflect on the issues. The idea is not to have an “expert” but someone who is active and has the experience. Please write to us if you are interested and we can talk more! The filming can take place connected to the workshop days and possibly later on.


Info about RåFILM

https://rafilm.se/en/about

Sign up to participate in the workshop by contacting Saara Särmä

This email address is being protected from spambots. You need JavaScript enabled to view it. or This email address is being protected from spambots. You need JavaScript enabled to view it.


Please indicate which session you’ll participate in and also let us know if you would be willing to be filmed. If you have any questions about the workshop, UNDO project, or the documentary, don’t hesitate to ask Saara!