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Procedure of the City of Helsinki in receiving child welfare notifications

Register number: OKV/1339/10/2020
Date of issue: 23.7.2020
Decision-maker: Deputy Chancellor of Justice
Subject: Social welfare and social insurance
Measure: Opinion

NB: Unofficial translation

The Deputy Chancellor of Justice presented his views on the service principle of the authorities, which is part of good governance, and on its appropriate arrangement in child welfare matters.

The complainant criticised the City of Helsinki's child welfare procedure in receiving child welfare notifications. According to the complainant, a written child welfare notification cannot be submitted to the child welfare services of the city. According to a report by the City of Helsinki, for the time being, municipal residents in Helsinki can submit a child welfare notification by contacting child welfare services by telephone, requesting contact for example by e-mail, sending a letter or visiting a child welfare unit. It is also possible to submit the notification via a secure mail sent by a social worker. For information technology reasons, it is not yet possible to submit a fully electronic child welfare notification.

According to the Deputy Chancellor of Justice, the appropriateness of a service requires that the service provided by the authority is available and appropriate. From the customer's point of view, it is important that they can easily contact the authority. In certain situations, it may be necessary to get in touch electronically either by email or using an electronic notification form if it is not possible for some customers to contact the authority by telephone, for example. Taking into account the service principle of administration, the appropriateness of services means that when a customer wishes to take care of their affairs electronically, such an opportunity to use services is guaranteed in the manner best suited to each service.

Easy access to the authorities' services for the customers of the administration may also be a prerequisite for the appropriateness of the authorities' official actions. For example, the Child Welfare Act imposes an obligation on the authorities to take, if necessary, very immediate and urgent measures to safeguard the child's development or wellbeing. The measures may be prompted, for example, by a child welfare notification submitted by a private individual, which should therefore be simple and easy to submit. At the same time, the authorities have a strict obligation under the Social Welfare Client Act to safeguard secrecy and protect the privacy and personal data of clients. In providing digital services, the authorities must also take into account, among other things, the services’ information security and data protection.

According to the complaint and the report received, the City of Helsinki would not currently have an appropriate electronic form for private persons to use for submitting child welfare notifications. The Deputy Chancellor of Justice considered that it can be considered a shortcoming not only from the perspective of the service principle in general but also, in particular, from the perspective of the urgency required in the processing of child welfare notifications. On the other hand, in order to protect information security and secrecy, the actions of the city could be considered appropriate in these circumstances. A child welfare notification can be submitted via secure email sent by a social worker. According to the city's announcement, next year it will introduce an information system that will enable the submission of a fully electronic child welfare notification in a secure manner.