Kela's e-services and applying for social assistance online

NB: Unofficial translation

The Deputy Chancellor of Justice drew Kela's attention to compliance with the provisions of the Administrative Procedure Act and the Act on the Provision of Digital Services in the implementation of its e-services.

According to the complainant, using and filling in the forms of Kela's e-services involves features that may make it more difficult for especially people with disabilities and illnesses to use the e-services. This is particularly the case with social assistance forms.

The Deputy Chancellor of Justice noted that the preparatory work for the Act on the Provision of Digital services has emphasised the accessibility of digital services in the public sector as part of the implementation of equality guaranteed by the Constitution. The accessibility of digital services also promotes the implementation of the guarantees of good governance laid down in the Constitution, which includes everyone's right to receive appropriate services and advice from the authorities.

Social assistance is the last-resort financial assistance for a social welfare member, the purpose of which is to secure the livelihood of a person and family and to promote their independent coping. According to the Deputy Chancellor of Justice, Kela has a particularly pronounced obligation and responsibility to ensure the accessibility and usability of digital services and e-services, taking into account the challenges, abilities and needs of different customer groups.

According to a report received from Kela, an online application for social assistance involves a page-specific 30-minute time cut. After this, the content filled in the application will be lost. According to Kela, information about the time cut is given at the beginning of the application. The Deputy Chancellor of Justice considered the time limit too short and the related loss of the information recorded in the application completely unreasonable for the user. It was particularly problematic that these features of the system may in practice cause difficulties and delays in applying for and receiving social assistance.

In its report, Kela has referred to the possibility for the user to temporarily suspend the filling in of the application, save the text as a draft and return to it within one month. The Deputy Chancellor of Justice considered that a storage period longer than one month would better meet the requirements of the accessibility legislation.

According to Kela, it is always possible for a customer using an online service to send a message to Kela via the e-services, and usually the customer is contacted from Kela if the processing of the matter so requires. However, the accessibility legislation requires that each authority has arranged sufficient support for the use of digital services and that it is actively offered to the customers of the administration. In the view of the Deputy Chancellor of Justice, a procedure in which a person using e-services receives advice on how to use the service only in situations where this is required from Kela's perspective does not meet the requirements of the accessibility legislation and the service and advisory principles of good administration.