A joint register is any structured set of personal data used for common purposes by several, in this case two, data controllers. In the case of a joint register, the data controllers jointly determine the purposes and means of the processing, so they also act as joint data controllers.

The change is based on the authorities’ more detailed interpretations of the EU’s General Data Protection Regulation (GDPR). As a result of these interpretations, SOK and S-Bank will be considered joint controllers for some of their common customer data.

Establishing a joint register enables SOK and S-Bank to produce services and benefits for the benefit of their joint customers. For example:

When S-Bank provides information about the customer’s deposit account for benefits payable in cash to the joint register, the cooperative is able to pay the cash benefits to the member’s benefit deposit account in S-Bank.

Similarly, when SOK provides the customer’s co-op member/service number to the joint register, S-Bank is able to produce a payment feature card for the customer as an S-Etukortti card and with the correct co-op member/service number to enable Bonus accumulation.

The scope of the joint register includes all co-op members or persons belonging to a co-op member household, who also have a customer relationship with S-Bank. The joint register also includes all S-mobiili users and customers who become co-op members through the “Liity Asiakasomistajaksi” (“Become a co-op member”) online service, regardless of whether they are also S-Bank’s customers, as these services are provided jointly by SOK and S-Bank.

The joint register is used to process a strictly limited set of data of SOK’s and S-Bank’s joint customers.

The following data are processed in the joint register:

• customer’s name, personal identity code and date of birth,
• customer’s language, gender information (if provided by the customer),
• contact information (e.g. address and phone number),
• information of permissions and prohibitions set by the customer (direct marketing prohibition, email and mobile phone marketing permissions, research survey prohibition and telephone marketing prohibition),
• information on the customer belonging to a co-op member household and the customer’s co-op member/service number,
• co-op member’s deposit account for benefits payable in cash and S-Etukortti cards with payment features.
• The S-mobiili usage data processed in the joint register includes, for example, information on the activation of S-mobiili and the devices on which the application is used, the digital footprint of the use of the service, and feedback on S-mobiili provided in the service.
• The information in the joint register is also included in S Group’s co-op member and customer register and in S-Bank’s customer register, where it is used in accordance with the purposes of data use of these registers.
• In addition to the information in the joint register, S Group’s co-op member and customer register and S-Bank’s customer register contain a lot of other information that is not disclosed to the joint register. For example, the joint register is not used to process S-Bank’s transaction data or S Group’s purchase data.

More information on the personal data included in the joint register can be found in the privacy statements of SOK and S-Bank as of March 2023.

The change to the joint register is not visible directly to customers, as S Group and S-Bank have also previously cooperated in the management of joint customers’ data. Previously, S Group and S-Bank have provided each other information regarding matters such as the contact information of joint customers so that the customer would not have to provide the information twice. In future, the contact information will be updated directly in the jointly maintained joint register of SOK and S-Bank. Data maintenance will be easier, and the development of our common services, such as S-mobiili, will become even smoother than before.

The data collected from the use of S-mobiili in the joint register enables better and more customer-oriented development of the service. Together, we can analyse the way different customer groups using S-mobiili utilise the service. Previously, the data collected on the use of S-mobiili’s retail services has been analysed by SOK, and the use of S-mobiili’s banking features has been analysed by S-Bank.

Customers will be informed of the establishment of the joint register mainly through SOK’s and S-Bank’s website. All customers in the joint register who have access to S-mobiili will also be informed of the change by a notice displayed in S-mobiili. In addition, we send information by email to those customers whose confirmed email address is known to us. No action is required from customers to be included in the joint register.

In March, we will also update the privacy statements of S Group’s co-op member and customer register and S-Bank’s customer register.

Careful and lawful data processing is a matter of pride for us and of the utmost importance – we want to be worthy of the trust of our customers.

We diligently protect personal data throughout its lifecycle by employing the appropriate information security and data protection mechanisms. Information security management in S Group and thus the protection of personal data is based on proactive risk management, on the basis of which we define adequate and lawful mechanisms to ensure information security and data protection.

We regularly provide training for our personnel who process personal data and ensure that our partners’ personnel also understand the confidential nature of personal data and the importance of secure processing.

We monitor and supervise our systems continuously and systematically. In the event of a possible information security incident, we will act in accordance with the requirements of the law and the defined process and, if necessary, notify the relevant authorities as well as the data subjects.

More information is provided both in the data protection information of S Group’s co-op member register S-Etukortti customers – S Group’s data protection website  (s-ryhma.fi) and in the data protection information of S-Bank’s customer register at  Data protection secures your personal data (s-pankki.fi).

If necessary, you can also contact the Data Protection Officer by email: tietosuojavastaava@sok.fi .

Below is a list of common information that S-Bank and SOK process for joint purposes.

* Personal data will also be processed as part of SOK’s co-op member and customer register and S-Bank’s customer register independently for their own purposes.