Privacy Notice
1. About the Privacy Notice
The Financial Management Authority manages state finances in accordance with Article 64 of the Public Finances Act, No. 123/2015.
The Authority is committed to protecting personal data and ensuring the security of the information it handles. This Privacy Notice explains how the Authority processes personal data, why it uses that data, the legal basis for processing it, and individuals’ rights under the Act on Data Protection and the Processing of Personal Data, No. 90/2018, and Regulation (EU) 2016/679 (GDPR).
Please send all privacy inquiries directly to the Authority’s Data Protection Officer at personuvernd@fjs.is. The Data Protection Officer will respond to inquiries about the handling of personal data and the Authority’s Privacy Notice.
All information about individuals, whether obtained from the individuals themselves, a public body, or an authority, is handled in accordance with the Act on Data Protection and the Processing of Personal Data, No. 90/2018, and Regulation (EU) 2016/679 of the European Parliament and of the Council.
This Privacy Notice is reviewed regularly. The privacy policy was first approved on 10 July 2018 and issued by the Director of the Authority.
The data controller is:
Financial Management Authority
Katrínartún 6
540269-7509
545-7500
The Financial Management Authority is responsible for ensuring that personal data is processed in its operations in accordance with the Act on Data Protection and the Processing of Personal Data, No. 90/2018, and Regulation (EU) 2016/679.
The Financial Management Authority’s Data Protection Officer provides further information about the processing of personal data and helps individuals exercise their rights.
Data Protection Officer
You can contact the Financial Management Authority’s Data Protection Officer by phone at 545-8800 or by email at personuvernd@fjs.is
Communications, reception and general administration
The Financial Management Authority processes personal data when individuals contact it through the request portal at island.is, send letters, call, visit its offices or otherwise communicate with it.
This processing may concern people submitting requests; former or current state employees; visitors; contacts at public bodies; suppliers; contractors; job applicants; company representatives; or others who contact the Authority.
The data may include:
Names and contact details
Workplace or relationship with a public body, company or other party
The subject of a request
Information in letters, emails or attachments
Information generated when answering calls or handling requests
Visitor information, such as name and workplace
Communication history and information about how a request was handled
In some cases, requests or attachments may contain sensitive personal data. The Authority processes only the information needed to direct or handle the request.
The data is processed to:
Receive requests
Answer calls and inquiries
Direct letters and requests to the appropriate recipient
Register and retain requests where required
Receive visitors and keep records of visits
Ensure security and traceability in communications with the Authority
Carry out general administration and provide services
The data comes mainly from individuals themselves, letters, calls, emails, the visitor registration system, the case management system, the state’s human resources and payroll systems, or other communication systems.
Access is given to Authority staff who need to receive, register, forward or handle requests. Service providers that operate or support the Authority’s case management, call handling, visitor registration or communication systems may also have access.
4.2 Applications for jobs at the Financial Management Authority
The Financial Management Authority processes personal data about applicants for jobs at the Authority. It does so to receive applications, assess applicants’ qualifications, communicate with applicants and complete the recruitment process.
The data may include:
Name, Icelandic identification number (kennitala) and contact details
Information in a CV and application
Education, work experience, qualifications and professional credentials
References or information from referees, where applicable
Results of assessments and interviews
Communications with the applicant
Documents needed to complete the hiring process if the applicant is appointed
The purposes are to:
Receive and manage applications
Assess applicants’ qualifications
Select a person for the position
Register and retain recruitment records
Respond to requests for information or reasons for a decision, where applicable
Complete the hiring process if an applicant is appointed
The data comes mainly from applicants, the recruitment system and referees named by applicants. Where permitted, it may also come from public registers or other sources.
Access is given to Authority staff involved in recruitment, such as human resources staff, managers and others who need to assess an application for the position. Providers of recruitment, document management or communication systems may have technical access under contract.
4.3 Payments, assessment and collection of public claims
The Financial Management Authority processes personal data in connection with payments, collection, assessment of public charges and other financial dealings related to its work. This processing may concern individuals who are customers, creditors, beneficiaries, applicants, representatives or contacts at public bodies, companies or other organizations.
The Authority mainly processes the following data, as needed in each case:
Identifying information, such as name and Icelandic identification number
Contact details, such as address, email address and telephone number
Bank details
Information about invoices, claims, payments, credit balances and refunds
Information about outstanding debts, arrears, collection and payment arrangements
Information relating to the assessment of public charges and associated reporting obligations, or to other claims
Information from communications with individuals, representatives, public bodies or others
Records needed for statutory oversight, auditing or reconciliation
Sensitive personal data is not generally processed for these purposes. In individual cases, however, information may relate to the type of service or claim established by the relevant public body—for example, a claim connected with health, education or social services. The Authority then processes only the information needed for payment, assessment or collection of the claim.
The data is processed so that the Authority can carry out its statutory and contractual duties, including to:
Pay invoices and other obligations of the State Treasury or state bodies
Handle refunds, credit balances, advance payments and corrections
Make grants, subsidies and other payments under agreements
Remit statutory payments and deductions
Establish, register and collect public charges and other claims
Allocate payments correctly and carry out reconciliations
Handle initial collection, collection of arrears, write-offs and payment plans
Answer inquiries and communicate as needed with individuals, representatives, public bodies and others
Verify information when needed for payment, assessment or collection
Provide records for statutory oversight or auditing, including to the Icelandic National Audit Office.
The data may come from:
The individual or their representative
State bodies or other public bodies that establish claims or provide information to the Authority
The tax authorities, where applicable
Employers or others involved in statutory reporting and remittances
Payment and collection systems
Public registers, such as the National Registry and Statistics Iceland
Other data sources where access is permitted
Access is given to Authority staff who need the data for their work, such as payment management, accounting, collection, assessment, reconciliation or oversight.
The data may also be shared with others when necessary or required by law, including:
The public bodies to which a claim or payment relates
Payment processors and banks
Debt collection providers
Municipalities, pension funds or other statutory recipients
District commissioners, Statistics Iceland or other authorities, where applicable
The Icelandic National Audit Office for statutory oversight and auditing
Data processors that provide the Authority with technical or operational services
4.4 Operation, development and support of digital services and electronic systems
The Financial Management Authority processes personal data when operating, developing, maintaining and supporting digital services and electronic systems used for the state’s financial, human resources, payroll and administrative work.
This processing may concern system users, state employees, contacts at public bodies, suppliers, payment recipients, employees receiving wages and other individuals whose information appears in the underlying systems.
The Authority mainly processes the following data, as needed in each case:
Name, Icelandic identification number and user ID
Email address, telephone number, public body, organisational unit and job role
Access permissions, roles and changes to access
Support requests, communications, error descriptions and attachments
System and activity logs, such as records of logins, changes, system jobs and errors
Information appearing in testing, development or operational data
Information from financial, payroll or human resources systems when needed for operations, support, testing or troubleshooting
In exceptional cases, this processing may involve sensitive personal data or confidential records, particularly if real data from payroll, human resources or financial systems is used for support, testing or troubleshooting. The Authority seeks to minimise the data used and restrict access.
Support requests and operational records may contain information supplied by users, including attachments or descriptions of issues. The Authority seeks to limit this information to what is needed to resolve the request, error or operational issue.
The data is processed to:
Operate and maintain the state’s financial, payroll and human resources systems
Provide system users with support and technical assistance
Create, change and close user accounts
Ensure appropriate roles and access controls
Identify and resolve errors or operational issues
Test changes and new features before they go into use
Ensure that actions in systems can be traced
Support information security and stable operations
Carry out the Authority’s statutory and contractual duties for the State Treasury and state bodies
The data is also processed to manage access to systems and file areas, receive and handle support requests, run technical processes, test changes, identify errors and keep the systems that the Authority operates or supports for state bodies running securely.
The data may come from:
The individual
System users
State bodies that use the Authority’s systems or services
Underlying financial, payroll and human resources systems
Support requests, work order systems and communications
System and activity logs
Service providers involved in operating or maintaining systems
Access is given to Authority staff who need the data for operations, support, development, testing, access management or security monitoring.
Service providers working for the Authority, such as operations, system or hosting providers, may also have access to the extent needed to provide their services. They must act under a contract and in accordance with the instructions of the Authority or another data controller, as applicable.
4.5 Data analysis, dashboards, data warehouses and public disclosure
The Financial Management Authority processes personal data to produce reports, dashboards, analyses and automated processes and, where applicable, to publish financial and human resources information. The purposes include improving oversight, supporting decisions, increasing efficiency and ensuring transparency in public finances.
The data depends on the task. It may include:
Name, Icelandic identification number or other identifiers
Public body, position, employment percentage, trade union membership and workplace
Financial information, such as account details, amounts and payments
Payroll or human resources information when needed for the analysis
Information from data warehouses, financial systems, human resources systems or reporting systems
Information about bidders or contracting parties in public procurement
Information from contracts or procurement documents
Aggregated or derived information in dashboards
Technical information generated by automated processes
For data analysis, dashboards and data warehouses, the Authority may process information about state employees, including pay, position, public body, employment percentage, workplace, job title, education, trade union membership and pension fund information. It may also process other information needed to give public bodies an overview, support management, produce reports and improve services.
When financial information is published, the Authority seeks to remove or limit personal data so that unnecessary or sensitive information is not disclosed.
The data is processed to:
Prepare reports and dashboards for management, oversight and review
Analyse financial, operational, payroll and human resources information
Support planning, financial reporting and administration
Improve oversight and decision-making in public procurement
Automate recurring processes
Publish financial information where permitted
Ensure transparency in the use of public funds
Reduce manual processing and the risk of errors
The data is also processed to produce human resources analyses, dashboards and summaries for state bodies, including to provide an overview of the state workforce, support planning and help public bodies carry out their statutory and administrative duties.
The data may come from:
State financial systems
Payroll and human resources systems
Data warehouses
Accounting and financial reporting records
The Authority’s procurement, contract, financial and reporting systems
State bodies that provide or review data
Automated processes and reporting systems
Access is given to Authority staff who need the data for analysis, reporting, dashboards, publication or oversight. Access to dashboards and analyses is restricted according to roles and need.
When aggregated information is shared, the Authority seeks to reduce the possibility of identifying individuals through access controls, aggregation and data minimisation.
If information is published—for example, in open accounting records—it may become available to the public. Before publication, the information is reviewed and cleaned to reduce the risk of disclosing personal data that should not be published.
4.6 Human resources, payroll and personnel administration for state bodies
The Financial Management Authority processes personal data when providing human resources, payroll and personnel administration services to state bodies (Part A bodies and other organisations that have a service agreement with the Authority). This processing concerns employees of state bodies, applicants for jobs with them, former employees, committee members and others who receive payments or entitlements through the state’s human resources and payroll systems.
The processing helps ensure that employee information and entitlements are recorded correctly, pay is calculated and paid correctly, payroll-related charges are remitted, and state bodies and their employees receive the services they need.
The Authority mainly processes the following data, where applicable:
Name, Icelandic identification number and contact details
Public body, trade union, position, employment percentage, job title and organisational unit
Hiring information, employment contracts and changes to a position or employment terms
Pay, pay grades, types of pay, deductions and wages paid
Bank details
Information about deductions made by the state and municipal collection authority
Tax card information, withholding tax, pension funds, supplementary pension savings, payroll tax and other payroll-related charges
Annual leave, length of service, entitlements and accrued leave obligations
Time records, attendance, leave and absences
Information relating to illness or other absences when it affects pay, entitlements or records
Payslips, annual wage statements, remittance reports and other statutory filings
Information needed for certificates, confirmations and employment history
Communications, support requests and records relating to inquiries from public bodies or employees
This processing includes sensitive personal data, such as information about trade union membership, illness and absences. The Authority processes it only to the extent needed for the task.
The data is processed to:
Manage human resources information for state bodies
Ensure that employment history, length of service and entitlements are recorded correctly
Calculate and pay wages
Issue payslips and ensure employees receive accurate information about their pay
Manage annual leave, attendance, time records, other leave and absences
Make payroll corrections and changes arising from collective agreements
Record payroll costs and carry out reconciliations
Submit annual wage statements, remittance reports, withholding tax information and other statutory information to the relevant recipients
Provide services to state bodies and answer inquiries
Issue employment certificates and confirmations where permitted
Develop, test and maintain the state’s human resources and payroll systems as needed
Settle pay, annual leave and other types of leave when employment ends
Provide or support a digital platform for state bodies to advertise jobs and conduct recruitment
Answer inquiries and provide confirmations relating to employment, pay, pension entitlements or other rights where permitted
If sensitive personal data, such as information about illness or absences, is processed, the conditions in Article 11 of Act No. 90/2018 must also be met. If information about criminal conduct is processed, the conditions in Article 12 of the Act must be met.
The data may come from:
The relevant state body
A manager or payroll officer at that body
Human resources, payroll, attendance and time recording systems
Public registers, such as the National Registry
The tax authorities, pension funds, supplementary pension funds, banks, trade unions and others, as applicable
Support requests, emails and other communications
Access is given to Authority staff who need the data for human resources, payroll, system, support or financial reporting tasks.
The data may also be available or shared with:
The state body where the individual works or has applied for a job
The employee
Managers and payroll officers at the relevant body, according to their roles and permissions
Banks, to make wage payments
The tax authorities, for withholding tax, annual wage statements and other statutory filings
Pension funds and supplementary pension funds
The Icelandic National Audit Office and other oversight bodies, where applicable
Service providers that operate or support human resources, payroll, attendance or document management systems
The tax authorities and the Icelandic National Audit Office for statutory filings, financial reporting, oversight or auditing
4.7 Self-service, time recording and services for employees of state bodies
The Authority also processes personal data when employees or managers at state bodies use self-service tools, time recording, attendance systems, a service portal or similar services.
The data may include:
Identifying information and contact details
Position, public body, manager and employment percentage
Information employees enter or update themselves, such as education, contact details and other employment-related information
Time records, attendance, absences, leave and annual leave
Requests, approvals, comments and communications
Activity logs and records of changes in systems
The purposes are to:
Allow employees to view and update their own information
Allow managers to approve and review information within their roles
Manage working hours, absences, annual leave and entitlements
Ensure that information affecting pay and entitlements is correct
Provide support and resolve inquiries or errors
The data comes from employees, managers, the relevant state body and the human resources, payroll and attendance systems used.
Access is given to the employee, relevant managers, payroll officers, the relevant state body and Authority staff who need the information for support, payroll processing, corrections or system operations.
4.8 Certificates, confirmations and inquiries about employment and pay
The Authority processes personal data when someone requests a certificate, confirmation or information about employment, pay, the end of employment, employment history or related matters.
The data may include:
Name and Icelandic identification number
Position, employment history, public body and employment percentage
Pay information
Information about the end of employment or entitlements
The content of the request and related communications
Records needed to verify the information
The data is processed to:
Answer inquiries
Issue certificates or confirmations
Provide information to authorised recipients
Serve state bodies and their employees
Meet legal obligations or respond to lawful requests
The data comes from human resources and payroll systems, the relevant state body, the employee, or earlier communications and records.
Access is given to Authority staff and staff at the relevant state body who need the data to handle the request. Information is shared only with a party authorised to receive it, such as the employee, the relevant state body or another authorised recipient.
4.9 Public procurement
The Financial Management Authority processes personal data in connection with public procurement, central purchasing agreements and contract services for state bodies and other public bodies. This processing may concern bidders, bidders’ contacts, contacts at contracting parties, subcontractors, bidders’ employees and contacts at public purchasers.
The Authority mainly processes the following data, where applicable:
Name, Icelandic identification number and contact details
An individual’s position, role or relationship with a bidder, purchaser or contracting party
Information in bids, tender documents, contracts and communications
Qualifications, experience, education, certifications or professional credentials of a bidder’s staff when these form part of a bid evaluation
Information about subcontractors and their contacts
Information about the status of public charges when relevant to an evaluation or eligibility requirements
Minutes, communications and other records relating to the preparation, conduct or follow-up of tenders and contracts
In limited cases, documents may contain more sensitive information or information subject to special protection—for example, criminal record information or details of specialised credentials or individual qualifications included in tender documents. Such data is processed only to the extent needed for the tender, contract or statutory process.
The data is processed to:
Prepare and conduct tenders
Provide tender services to state bodies and other public bodies
Receive, review and evaluate bids
Assess the eligibility of bidders and, where applicable, their employees or subcontractors
Ensure that tenders and contracts are handled correctly
Manage central purchasing agreements and framework agreements
Analyse the shared purchasing needs of public bodies
Respond to requests and support inquiries about procurement and contracts
Retain records for traceability, oversight and records management
The data may come from:
Bidders
Contacts at bidders or contracting parties
Subcontractors
Public purchasers
Tender and contract management systems
Work order and communication systems
Public registers or other sources where collecting the information is permitted
Access is given to Authority staff involved in procurement, tenders, contracting, support, analysis or oversight.
The data may also be shared with:
The public purchaser concerned by the tender or contract
Bidders or contracting parties to the extent provided for by tender and procedural rules
The Public Procurement Complaints Committee if it considers the matter
Other authorities or oversight bodies where permitted by law
Data processors that operate or support tender, contract, document management or communication systems
The Financial Management Authority processes personal data primarily when necessary to meet its legal obligations or to perform tasks in the public interest and exercise official authority, under items 3 and 5 of Article 9 of Act No. 90/2018 and points (c) and (e) of Article 6(1) of the GDPR.
Where processing relates to contractual payments or a contractual relationship, it may also be based on item 2 of Article 9 of Act No. 90/2018 and point (b) of Article 6(1) of the GDPR, for example in connection with hiring staff and entering into contracts.
Where processing relates to an employment relationship, a job application, payment of wages, or the exercise of rights and fulfilment of obligations under an employment relationship, it may also be necessary for a contract or for steps taken before entering into a contract, under item 2 of Article 9 of Act No. 90/2018 and point (b) of Article 6(1) of the GDPR.
Processing for security and property protection purposes, including CCTV and visitor registration, is based on the Authority’s legitimate interests in security, reception and the organisation of visits, under item 6 of Article 9 of Act No. 90/2018, to the extent that this legal basis applies to the processing concerned.
Where sensitive personal data or information about criminal conduct is processed, the additional conditions in Article 11 or 12 of Act No. 90/2018 must also be met, as applicable.
The Financial Management Authority is required to transfer records to a public archive under the Public Archives Act.
As a public body, the Authority retains records and, where applicable, transfers them to a public archive in accordance with the Public Archives Act, records retention schedules and rules on public records management. Transferring records to the National Archives of Iceland or another public archive is part of statutory records management; it is not a separate service provided to individuals.
Personal data is retained in accordance with the law, records management rules and approvals issued by the National Archives of Iceland.
Retention periods vary according to the nature of the information and the purpose of processing.
Data not covered by the Public Archives Act, such as test data, working copies, temporary export files and attachments to support requests, is kept no longer than necessary.
The Financial Management Authority applies appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, loss or other unlawful processing.
These measures include:
Access controls
User authentication
Activity logging
Information system security
Staff training
Regular risk assessments and security monitoring
Under Act No. 90/2018 and the GDPR, individuals may have rights including:
Access to their personal data
Correction of inaccurate data
Restriction of processing in certain circumstances
Objection to processing in certain circumstances
Data portability when the legal conditions are met
These rights may be restricted by law.
Requests to exercise these rights should be sent to the Financial Management Authority or its Data Protection Officer.
Individuals who believe that their personal data is being processed unlawfully may lodge a complaint with the Icelandic Data Protection Authority.
Further information is available at www.personuvernd.is.
The Financial Management Authority may update this Privacy Notice when its activities, its processing of personal data or the applicable rules change.
The latest version is always published on the Financial Management Authority’s website.
