Loan information

Purpose of processing data

Whose data do we process?

Where does the data come from?

What data do we process?

On what basis do we process data?

Retention of data

Your data protection rights regarding the processing of personal data

Purpose of processing data

The Positive credit register is a national register containing information about loans. The register’s aim is to prevent over-indebtedness by ensuring that reliable loan data is available to lenders especially for purposes of assessing the loan applicant’s creditworthiness during the lending process, and by improving natural persons’ ability to control their own finances. In addition, some authorities use the register’s data to supervise and monitor the stability of the financial markets and the credit markets, support decision-making and compile statistics.


Whose data do we process?

The Positive credit register contains data on natural persons who have a Finnish personal identity code and a place of residence in Finland. Businesses with the reporting obligation can also report loan data on natural persons who do not have a place of residence in Finland, provided that the person has a Finnish personal identity code and, in addition, receives income from Finland or has another special bond to Finland when the loan is granted.


Where does the data come from?

We receive loan data from lenders and other businesses that are obliged to submit reports to the Positive credit register. Loan data can be reported to and stored in the register as of 1 February 2024.

Businesses with the reporting obligation are defined in the Act on the Positive Credit Register (739/2022). They include:

  • entities supervised by the Financial Supervisory Authority under the Act on the Financial Supervisory Authority (878/2008), Finnish branches of foreign EEA supervised entities, and foreign supervised entities that provide services in Finland but do not have a Finnish branch
  • lenders and loan brokers entered into the Financial Supervisory Authority’s register in accordance with the Act on the Registration of Certain Credit Providers and Credit Intermediaries (186/2023)
  • other businesses to which the lender’s rights arising from a loan contract reported to the register are transferred (reassignees).

Kela is required to submit reports on guarantee receivables referred to in section 38 of the act on financial aid for students (Opintotukilaina 65/1994).

The names and Business IDs or foreign business IDs of operators that report loan data to the register can be found at Data notifiers on the Positive credit register's website.

The data in the Positive credit register is not real-time data. According to the Act on the Positive Credit Register, data on a new loan contract must be reported to the register no later than on the day following the day when the loan contract was concluded. When the contract has been concluded, any loan transactions (payment transactions, delayed amounts, acceleration of the loan, end and transfer of the loan) and changes to the loan contract data must be reported within two business days.


What data do we process?

The data processed in the Positive credit register is laid down in the Act on the Positive Credit Register. The register contains data on consumer credits and loans comparable to consumer credits. This means that the register does not contain data on all invoices and credits.

A consumer credit means credit which, by agreement, is granted or promised to the consumer by a business in the form of a loan, deferred payment or another corresponding financial arrangement and on which interest or other charges are collected. An extension for payment granted in commodity trading is not a consumer credit, so data on such agreements is not found in the register. Further, the Positive credit register does not contain data on promised loans, interest-free and expense-free loans, credits granted by pawnbrokers, or social loans.

Loans comparable to consumer credits refer to leases or other such contracts by which goods are transferred to the consumer’s control and according to the terms and conditions of which the cash price and loan expenses will be paid during the lease period or the consumer can otherwise become the owner of the goods at the end of the contract. The Positive credit register calls such contracts leasing contracts.

A credit which a party other than a lender grants or promises to grant to the consumer as a loan, deferred payment or another corresponding financial arrangement is also regarded as comparable to a consumer credit if the business operator brokers the credit to the consumer. In those cases, the lender acts as a peer-to-peer loan broker.

The register also contains data that Kela has reported on guarantee receivables for student loans. Guarantee receivables for a student loan refer to a debt that Kela pays to the lender based on a government guarantee. If the borrower does not pay a government-guaranteed student loan or its interest on time, Kela will pay the student loan to the lender. After than, Kela will collect the amount it paid from the borrower.

  • basic information
  • lump-sum loan information
  • running-account loan information
  • leasing information
  • interest information
  • information on collateral
  • amortization information and deferment periods
  • information on delayed amounts
  • information on a debt arrangement and business restructuring
  • income information
  • information on the end and transfer of a loan.

Lenders will also report changes to the above information to the register.

According to law, lenders are obliged to report loan data to the register only if it is reasonably available. Because of this, some individual data may not be found in the register.

Basic information

  • borrower’s personal identity code
  • lender's name, and the marketing name or auxiliary business name that the lender has used when marketing the loan
  • lender’s Business ID or foreign business ID
  • loan number and type of loan number
  • information on whether the lender acts as a peer-to-peer loan broker
  • number of debtors
  • date of conclusion
  • loan type: lump-sum loan, running-account loan, leasing or guarantee receivable for a student loan
    • A running-account loan is a consumer credit that is continuously available to the borrower up to a pre-defined credit limit. Running-account loans include credit cards, deferred debit cards and different accounts with credit facilities, for example. Lump-sum loans include other than running-account loans, such as a home loan or a student loan.
  • loan currency
  • information whether the loan is a consumer credit within the scope of chapter 7 of the Consumer Protection Act, a consumer credit related to residential property within the scope of chapter 7 a of the Consumer Protection Act, or other than a consumer credit
  • information if the loan is a goods or services related credit
    • A goods or services related credit is a consumer credit that a seller, a service provider or a business acting on their behalf has granted for the acquisition of a consumer commodity.
  • one-time expenses paid as the loan contract is concluded
    • One-time expenses include, for example, expenses and fees charged for a loan application and conclusion of a loan contract, and charges for the use of a means of payment.
  • information whether the loan has been transferred from another lender
  • income data established during the lending process.
    • Lenders report income data that has been established for purposes of assessing the borrower’s creditworthiness. The lender has received the data directly from the borrower or in another way. The income is reported as monthly income and separated into gross income and net income.

Lump-sum loan information

Lump-sum loans include other than running-account loans, such as a home loan or a student loan.

  • purpose of use of the loan: home loan, home loan for first home, home loan for leisure house, home loan for investment purposes, student loan, consumer credit for the purchase of a vehicle or craft, other consumer credit, other loan, or guarantee receivable for a student loan
  • final due date of the payment plan
  • payment method: fixed-size amortization, fixed-size payments, annuity, balloon, bullet or other
  • amortization frequency
  • amount issued
  • amount paid
  • loan balance.
    • Loan balance means the remaining balance. The lender updates the loan balance when reporting payment transactions related to the loan.

Running-account loan information

A running-account loan is a consumer credit continuously available to the borrower up to a pre-defined credit limit. Running-account loans include credit cards, deferred debit cards and different accounts with credit facilities, for example.

  • credit limit
  • amount of loan balance
    • Amount of loan balance is the unpaid debt. Lenders report the amount of loan balance for the running-account loan according to the situation on the calendar day following the monthly due date or, if there is no monthly due date, on the last calendar day of the month.
  • value date for the amount of loan balance.

Leasing information

Leasing includes lease contracts or other contracts under which goods are transferred to the consumer’s control and according to the terms and conditions of which the cash price of the goods and the loan expenses will be paid during the lease period or the consumer can otherwise become the owner of the goods at the end of the contract.

  • start date of the contract period
  • monthly instalment
  • interest included in the instalment
  • other expenses included in the instalment
    • Other expenses include, for example, expenses paid for supplementary services falling within the scope of the leasing contract. Interest is not included.
  • transaction price.
    • The transaction price is reported to the register if the leasing contract requires that the borrower should redeem the leased item at the end of the contract period.

Interest information

Lenders report the following interest information on running-account loans and on lump-sum loans other than guarantee receivables for student loans:

  • total interest rate
    • For example, if a loan is subject to a margin interest rate of 1% plus the bank’s reference rate, which on the date of conclusion is also 1%, lenders report that the total interest rate is 2%.
  • margin interest rate
    • The margin interest rate is the part of interest that is defined specifically for the customer in the loan contract.
  • interest type: Euribor rate, reference rate determined by the bank, other variable reference rate, fixed interest or interest-free
  • length of the period for interest determination
    • This data is stored in the register if the interest type is Euribor rate.
  • end date of the period for a fixed interest rate
  • type of linkage to a benchmark interest rate after the period for a fixed interest rate: Euribor rate, reference rate determined by the bank or other variable rate
  • lower limit of the interest rate corridor
  • upper limit of the interest rate corridor
  • interest rate cap
  • end date of interest rate restriction
  • effective interest rate on the date of conclusion.
    • Effective interest rate means the annual interest rate calculated in accordance with the Consumer Protection Act.

Lenders report only expenses that are taken into account in the calculation of the effective interest rate. Expenses resulting from breaches of contract, such as late-payment interest, are not reportable expenses.

Information on collateral

Lenders report the following information on collateral for loans other than leasing contracts:

  • information whether collateral is included in the loan contract
  • type of collateral: residential property, other immovable property, hire-purchased item, other moveable property, other collateral, personal guarantee, government guarantee or other guarantee
  • guarantor’s personal identity code.

Amortization information and deferment periods

  • loan number and type of loan number
  • loan type
  • total interest rate
    • The register does not contain interest data on guarantee receivables for a student loan.
  • amortization paid
  • interest paid
    • The register does not contain data on late-payment interest.
  • other loan expenses paid
    • Lenders report to the register the loan expenses that are taken into account in the calculation of the effective interest rate according to the Consumer Protection Act.
  • payment date
  • remaining loan balance
  • payment transaction timestamp.
    • The timestamp of a payment transaction indicates when the transaction was reported to the register. The register arranges the payment transactions in the correct order based on timestamps.

  • loan number and type of loan number
  • loan type
  • total interest rate
  • amount of loan balance
    • Lenders report the amount of loan balance for a running-account loan according to the situation on the calendar day following the monthly due date or, if there is no monthly due date, on the last calendar day of the month.
  • value date for the amount of loan balance
  • interest paid
    • The register does not contain data on late-payment interest.
  • other loan expenses paid
    • Lenders report to the register the loan expenses that are taken into account in the calculation of the effective interest rate according to the Consumer Protection Act.
  • payment date.

The register does not contain payment transactions related to leasing contracts.

In addition, lenders report the start and end dates for separately agreed deferment periods of lump-sum loans and running-account loans. If a deferment period is an integral part of the loan contract and requires no separate agreement and if it is under the borrower’s control, then the period is not reported to the register.

Information on delayed amounts, and loan acceleration

Information on instalments that are more than 60 days late from the original due date are reported to the Positive credit register as delayed amounts.

  • loan number and type of loan number
  • unpaid amount of the instalment
  • original due date of the delayed instalment.

  • loan number and type of loan number
  • date of acceleration.

Information on a debt arrangement and business restructuring

With regard to all loans, the Positive credit register contains information whether the borrower is in a debt arrangement or business restructuring confirmed by a court of law and whether the loan is included in a debt arrangement payment plan or a business restructuring program. 

  • basic information
  • information on collateral
  • information on the end of the loan.

If the debt arrangement or business restructuring program lapses, the lender will inform the register to that effect. In that case, the lender must update all loan data, if needed.

Income information

The Positive credit register stores income data that is necessary for the calculation of a natural person's gross and net income. The data is received from the Incomes Register. Read more about the processing of income data received from the Incomes Register.

In addition to the income data received from the Incomes Register, the register contains income data that has been established for purposes of assessing the borrower’s creditworthiness. The lender has received the data by asking directly from the borrower or in some other way. The income is reported as monthly income and separated into gross income and net income.

Information on the end and transfer of a loan contract

Lenders report information on the end of a loan contract and on the transfer of a loan contract to another party with the reporting obligation.

  • loan number and type of loan number
  • information that the loan has ended
  • end date.

  • loan number and type of loan number
  • information that the loan has been transferred to another lender
  • type of reassignee ID code and identifier
  • reassignee's name
    • Lenders report this data if the type of reassignee ID code is foreign business ID.
  • reassignee's country code.
    • Lenders report this data if the type of reassignee ID code is foreign business ID.

On what basis do we process data?

Personal data is processed in order to comply with the statutory obligation set for the Incomes Register Unit (General Data Protection Regulation (EU 2016/679), Article 6(1)(c)). The processing is provided for in the Act on the Positive Credit Register (Act on the Positive Credit Register 739/2022).


Disclosure of data

According to the Act on the Positive Credit Register, the data stored in the register is confidential, with the exception of the name, Finnish Business ID or foreign business ID of the lender with the reporting obligation. We disclose data from the Positive credit register to lenders and authorities only for the purposes laid down in the Act on the Positive Credit Register. The register starts disclosing data on 1 April 2024.

Disclosing data to lenders

The Act on the Positive Credit Register provides for the disclosure of data to lenders and other businesses with the right of access to data. We disclose data only for the purposes laid down in the Act on the Positive Credit Register. We disclose data in the form of credit register extracts.

Businesses with the right of access to data

Businesses with the right of access to data include:

  • businesses under the supervision of the Financial Supervisory Authority that have been entered into the register of lenders and loan brokers and have the duty to report loan data to the register (read more about these businesses)
  • other lenders that have the obligation to test the consumer’s creditworthiness or check the accuracy of consumer-related data under the Consumer Protection Act.

To request a credit register extract, the business must have a data permission granted by the Incomes Register Unit

Credit register extract’s purposes of use

The Act on the Positive Credit Register provides exhaustively for the purposes of use for which data may be disclosed from the register.

1) Testing the consumer’s creditworthiness

The lender can request a credit register extract when the Consumer Protection Act obliges them to test the consumer’s creditworthiness. The lender is obliged to test the consumer's creditworthiness before a loan contract is concluded, and after the conclusion of a loan contract if the loan principal or credit limit is significantly increased.

2) Checking the accuracy of the consumer’s data

The lender can request a credit register extract when the Consumer Protection Act obliges them to check the accuracy of the consumer’s data. The lender is obliged to check the accuracy of the data on the consumer when the consumer and the lender agree on increasing the loan principal or credit limit after the loan contract has been concluded.

3) Testing the consumer’s creditworthiness when the loan contract is being amended

Businesses that have a duty to submit reports to the register can request a credit register extract when the debtor requests a change other than an increase of the loan principal or credit limit to the terms of the loan. In order that a credit register extract could be requested, the change must require an assessment of creditworthiness.

Reassignees are not entitled to request credit register extracts for this purpose, even though they are obliged to report loan data to the register.

4) Granting or accepting a guarantee or a third-party security

Businesses that have a duty to submit reports to the register can request a credit register extract for the purpose of granting or accepting a third-party security.

Reassignees are not entitled to request credit register extracts for this purpose, even though they are obliged to report loan data to the register.

A business operator must state the purposes of use of the credit register extract when submitting a request. The business operator is responsible for seeing that the confidential data received from the Positive credit register is processed in compliance with law. The credit register extract may be used only for the purpose for which it was disclosed from the register. Notwithstanding the above, however, data may also be used for the purposes below by virtue of the Act on the Positive Credit Register:

The lender may share data they have received from the Positive credit register with the State Treasury when applying for compensation under the Act on State Guarantees for Owner-Occupied Housing Loans (204/1996).

The lender may disclose credit register extract data received from the Positive credit register to the guarantor and the security provider (pledgor). The disclosure of data may be based either on the lender’s obligation to report data laid down in law or on the data subject’s consent that their data may be disclosed.

It is part of the lender’s statutory obligation to report information that before they provide a guarantee, they must report the debtor’s such obligations and other circumstances relating to the debtor’s ability to pay that can be deemed to be of interest to the guarantor. During the period of validity of the guarantee, the guarantor also has the right to ask the lender to provide information on these matters. However, the guarantor's request does not entitle the lender to separately request data from the Positive credit register.

Data can be disclosed to third-party security providers in a similar way as to guarantors. In the provision of third-party security, the security provider pledges their property with the creditor as security for the performance of another person’s obligations.

The right to disclose data that the lender has received from the Positive credit register may also be based on the data subject’s consent. Based on consent, the lender can disclose credit register extract data to parties providing commercial housing loan guarantees, for example.

The lender may use the loan applicants’ data received from the Positive credit register for purposes of testing creditworthiness in order to meet certain obligations. These obligations, relating to credit risk management, are laid down in law.

Content of the credit register extract

Identifying data

  • personal identity code of the individual whose data the register extract contains
  • identifier of the organisation that requested the register extract.

Summary of loan data

  • number of lenders and peer-to-peer loan brokers that have issued or brokered loans to the person
  • number of loan contracts that the pers
  • total amount of payments paid last
    • The amount contains the most recently paid amortization, interest payment or expense amount of each loan added together. However, the amount does not contain payments related to loans that are included in a debt arrangement payment plan or business restructuring program.
  • leasing contracts’ monthly payments in total
  • number of loans where the person is a guarantor.

Loan details

  • loan type: lump-sum loan, running-account loan or leasing
  • date of conclusion
  • number of debtors
  • loan currency
  • information whether a collateral is included in the loan contract; if yes, the type of collateral
  • start and end date of a deferment period
  • due date of an instalment that is at least 60 days late, and the unpaid amount of the instalment
  • information on loan acceleration
  • the following information if the loan type is leasing:
    • start date of the leasing contract if the date is not the same as the date of conclusion
    • transaction price if redemption is required by the contract
  • the following information if the loan type is lump-sum loan:
    • loan’s purpose of use
    • final due date of the payment plan
    • amount issued and amount paid
    • loan balance
    • amortization frequency
    • payment method if the loan is to be paid as a lump sum (bullet) or if the last instalment is notably larger than the regular instalments (balloon)
  • the following information if the loan type is running-account loan:
    • credit limit
    • amount of loan balance, and the value date.

Income information

  • An individual’s gross and net income for the past 12 full calendar months, separated into wages and benefits.

Voluntary ban on credits

  • If a person has set a voluntary ban on credits, the ban and the reason for it are indicated on the register extract. Voluntary bans on credits can be set as of 1 April 2024.

Information that the person has requested restriction of personal data processing under Article 18 of the General Data Protection Regulation.

Credit register extracts are displayed in the e-service

You can view the credit register extracts requested about you in the Positive credit register’s e-service. You can also check the content of the credit register extract there, and see who has requested the register extract, when and for what purpose.

Disclosing data to authorities

We disclose loan data to the Bank of Finland, the Financial Supervisory Authority, the Finnish Competition and Consumer Authority, the Consumer Ombudsman and Statistics Finland.

Bank of Finland

  • ensuring the reliability and efficiency of the financial system, and developing the financial system
  • preparing and publishing statistics necessary for the operations of the Bank of Finland

Financial Supervisory Authority

  • monitoring and evaluating financial markets, and issuing regulations regarding the financial markets
  • supervising financial markets and lenders, including supervision of credit risks and consumer protection
  • compiling data on the financial position of parties operating on the financial markets

Finnish Competition and Consumer Authority

  • establishing the competition conditions on credit markets

Consumer Ombudsman

  • supervision of compliance with consumer protection legislation, including the supervision of contractual terms, compliance with contractual terms, assessment of creditworthiness and making of credit decisions

Statistics Finland

  • preparation of statistics

We disclose data to the Bank of Finland, the Financial Supervisory Authority and the Finnish Competition and Consumer Authority in pseudonymised form. This means that the personal data cannot be linked to an individual without additional information. We disclose data to the Consumer Ombudsman both in pseudonymised form and as identifiable data. The data disclosed to Statistics Finland is not pseudonymised.

The disclosure of data is based on the Act on the Positive Credit Register, which explicitly lays down the tasks for which authorities can receive data from us. After the data has been disclosed, the authorities process the data in the capacity of controllers. Further information about the processing of personal data is available on the authorities' own websites.

By virtue of the Act on the Positive Credit Register, we can also disclose data to the Financial Supervisory Authority and the Regional State Administrative Agency of Southern Finland for the supervision of business operators’ obligation to sign up and submit reports.

Disclosure of data by virtue of the Act on Openness

According to the Act on the Positive Credit Register, we can also disclose data for the following purposes laid down in the Act on the Openness of Government Activities (621/1999, Act on Openness):

  • right of access to data of the party concerned
  • right of access to a document pertaining to the party concerned
  • provision of executive assistance
  • processing of advance information, a preliminary ruling or a complaint.

Processors

The Positive credit register has been implemented on the Microsoft Azure cloud service platform. We use the following service providers for application management services, such as troubleshooting: Innofactor Software Ltd, Gofore Plc, Gofore Verify Oy and Advania Finland Oy. When processing personal data, application management uses a service management system provided by ServiceNow.

Transfer of personal data to third countries

In principle, we do not disclose data to countries outside the EU/EEA. However, in exceptional individual cases, Microsoft may have access to personal data during support and maintenance activities. In data transfer, the transfer basis under the General Data Protection Regulation is the European Commission's decision on the adequacy of data protection under Article 45(1) (Adequacy decision for the EU-US Data Privacy Framework, C(2023) 4745 final) or, where necessary, standard contractual clauses published by the European Commission.


Retention of data

Data retention periods are defined in the Act on the Positive Credit Register. With regard to data retention, we comply with the Tax Administration's information management plan. After the end of the retention period, data is either destroyed or archived in accordance with the archives act (Arkistolaki 831/1994).

We will delete the loan data reported by lenders and other parties with the reporting obligation two years after the end or cancellation of the loan. Amortization data will be deleted two years after it is stored in the register. However, as regards the balance and deferment periods of lump-sum loans, the two-year retention period is calculated from the end of the loan.

We will delete the information about delayed amounts from the register 30 days after the lender has reported that the delayed amount has been paid or the loan has ended. When reporting a loan as accelerated, the lender must also remove any delayed amounts that have been reported to the register.

We will delete the information about acceleration 30 days after the lender has reported that the accelerated loan has been paid up in full or that the loan has otherwise ended. We will also delete the information about a debt arrangement or business restructuring 30 days after the lender has reported that the payment plan or restructuring program has ended or lapsed or the loan has ended.

After the lender has reported that the delayed amount has been removed or the accelerated loan has been paid up, that the debt arrangement payment plan or business restructuring program has ended or lapsed, or that the loan has ended, data relating to them will no longer be disclosed on credit register extracts.

We delete credit register extracts five years after sharing them with lenders.


Your data protection rights regarding the processing of personal data

As a controller, the Income Register Unit is responsible for enforcing your data protection rights based on the EU's General Data Protection Regulation. You can make a free-form written request regarding your data protection rights and send it to us to the address below:

POSITIVE CREDIT REGISTER
P.O. BOX 2
FI-00055 Incomes Register

You can find more information about your data protection rights on the website of the Office of the Data Protection Ombudsman.

If you need help in exercising your rights, you can contact our customer service.

Right to view personal data

You have the right to know if we are processing your personal data. You are also entitled to receive a copy of your personal data that we process.

You can submit a request to view your personal data with the form below.

Request to view personal data

You can access the Positive credit register’s data through the e-service for private individuals. There you will see the latest loan data reported by lenders, and the credit register extracts requested about you. The e-service will be available as of 1 April 2024. To use the e-service, you will need your online banking codes, a mobile certificate or a certificate card.

Right to rectify data

You have the right to request us to rectify your inaccurate or incorrect personal data without any undue delay.

The loan data in the Positive credit register is as reported by lenders. You can see the most recent data reported by a lender in the Positive credit register’s e-service. The credit register extract is always generated based on the most recent data.

If you detect an error in your loan data, it is important to correct it, because lenders use the register’s data when assessing your creditworthiness. To correct the error, you can contact the Incomes

Register Unit or the lender who submitted the erroneous data. Usually the quickest way to settle the matter is to contact the lender directly. When you contact us, we will investigate the matter with the lender and, in the first place, ask the lender to correct the error by reporting the correct data to the register.

Right to restriction of processing

If you think the data we are processing about you is incorrect, if the data is processed against the law or if you have opposed the processing of your data, you can request us to restrict the processing of your personal data.

The Act on the Positive Credit Register separately prescribes that we can disclose data to authorities, lenders and other parties having the right of access to data even in situations where the data subject has denied the accuracy of their data and required that the processing should be restricted. In such a case, the credit register extract delivered to the lender will show that you have requested the restriction of processing. This will be indicated on the credit register extract until the matter is settled. The lender or other party using the credit register extract can thus take into account that the accuracy of the data has been questioned.

Right to file a notification with the supervisory authority

You have the right to file a notification with the Data Protection Ombudsman regarding the processing of your personal data. Further information and instructions on how to file a notification are available on the website of the Office of the Data Protection Ombudsman.

Page last updated 2/1/2024