Acting on behalf of another person
Many authorities and other organisations use Suomi.fi e-Authorizations. Each organisation independently determines whether they will allow people or companies to act on behalf of another person in their service and who can use the service. When you log in to a e-service (for example, Kela's My Kanta), your right to act on behalf of another party is verified from the Population Information System and the authorisation register using Suomi.fi e-Authorizations.
The guardians entered in the Population Information System for an underage child can usually act on behalf of the child without a separate mandate.
If the guardian of a child cannot act on behalf of the child:
- They can check the Digital and Population Data Services Agency’s Personal Data service to verify whether they have been registered as the child's guardian.
- If they are listed as the guardian of the child, they can ask the Digital and Data Services Agency if another guardian has been appointed for the child or if a joint custody agreement or order concerning the child is in force.
Information on whether a child has been taken into care or on non-disclosure orders applying to the child or the child’s other guardians is not disclosed to the e-service because this is classified as sensitive.
There may be different terms and conditions that apply in e-services
The authority responsible for the e-service may also have set terms and conditions for acting on behalf of underage persons. If there are special terms and conditions and just one of them is breached, you may not act on behalf of your child.
These conditions may, for example, be:
- Only the child's legal guardian entered in the Population Information System can act on behalf of a minor.
- If a valid joint custody agreement or order is in place regarding custody of the child, the content of the agreement or order will determine whether the guardian can act on behalf of the child. Joint custody can take various forms. A person can act on behalf of a child if the agreement only relates to living arrangements (custody) or only one guardian for the child is listed in the Population Information System. It is not possible for a person to act on behalf of a child, if the agreement or order also takes a stand on matters other than those related to the child's living arrangements. This is because these special conditions are entered in the register's free-form text box and are not yet in Suomi-fi e-Authorizations.
- A child’s parent does not have the right to act on behalf of a child who has been taken into care.
- If a child has been issued a non-disclosure order, none of the child’s guardians can act on behalf of the child.
- If all of the child’s guardians have a non-disclosure order, none of the guardians can act on behalf of the child. If only one of the guardians has been issued with a non-disclosure order, the guardian issued with the order can act on behalf of the child. The purpose of these conditions is to protect the information in the non-disclosure order.
The age of the dependant may also restrict use of an e-service. For example, the e-service may have imposed a condition stating that no one can act on behalf of a person aged 10 or over. The e-service provider (such as Kela) always decides on the age limit for their e-services.
The persons who can act on behalf of someone else when granted a mandate in Suomi.fi e-Authorizations include:
- A person who is 18 or older can manage the matters listed in mandate on behalf of another person.
- If the e-service requires for acting on behalf of the dependent the consent of all the guardians, one of guardians can manage affairs of the minor if all the guardians have granted this person a mandate to act on behalf of the dependent. However, a child's non-disclosure order cannot be overridden by a separate mandate.
The assignee must use personal Finnish identification tokens to identify themselves in the service.
Mandates can be granted in Suomi.fi e-Authorizations by persons over the age of 18, who have a Finnish personal identity code and who can identify themselves in the service with Finnish identification tokens.
A person under guardianship cannot grant mandates to another person to act on their behalf. In addition, the guardian cannot also grant mandates on their client’s behalf.
The estate of a deceased person with no business ID cannot mandate anyone to manage the estate’s affairs. If an estate of the deceased has a business ID, the estate can grant mandates via the Mandate service provided by officials. More information on the Acting on behalf of a company or an organisation page
There are cases when you do not have the right to act on behalf of another person or the matter cannot be reliably checked from register data. For reasons related to data protection, only information on whether transactions are possible or not is given for the e-service.
You cannot use services that use Suomi.fi e-Authorizations service on behalf of another person in the following situations:
- The assignee is under guardianship.
- For the time being, the guardian cannot act on behalf of a person under guardianship, because the Suomi.fi e-Authorizations do not yet receive information on the content and scope of the guardianship from the registers. Contact the organisation responsible for the e-service directly in matters relating to acting on behalf of a person placed under guardianship.
- A guardian is appointed to a person over the age of 18, who has granted the mandate. In such a case the previously given mandates will be invalidated, and they can no longer grant mandates to other people.