Equality plan for customersat the Digital and Population Data Services Agency

According to section 6 of the Constitution of Finland (731/1999), everyone is equal before the law. No one shall, without an acceptable reason, be treated differently from other persons on the ground of sex, age, origin, language, religion, conviction, opinion, health, disability or other reason that concerns his or her person. 

Under section 4 of the Act on Equality between Women and Men (Equality Act, 609/1986), the authorities must in all their activities promote equality between women and men purposefully and systematically and create and consolidate administrative and operating practices that ensure the advancement of equality between women and men in the preparatory work undertaken on different matters and in decision-making.

Under section 5 of the Non-Discrimination Act (1325/2014), it is the duty of the authorities to promote equality by evaluating, in particular, the realisation of equality in their activities and taking the necessary measures to promote the realisation of equality. These measures must be effective, expedient, and proportionate, taking into account the authority’s operating environment, resources, and other circumstances. 

This operational equality plan examines the customer service provided by the Digital and Population Data Services Agency (DPDSA) as extensively as possible from the perspective of equality. The DPDSA’s operations are organised nationally. Therefore, the plan applies to all customer services provided by the DPDSA, regardless of their location or service channel. Under the Act on the Provision of Digital Services, the authorities must plan and main-tain their digital services in a way that ensures their information security, data protection, discoverability, and ease of use. Under the Act on the Provision of Digital Ser-vices, the service provider must ensure the perceptibility and comprehensibility of the contents of its digital services as well as the manageability and reliability of its user interfaces and navigation practices, in accordance with accessibility requirements. These accessibility requirements are defined in the Official Journal of the European Union.  

Our operations are based on equal and responsible customer service and cost-effective solutions. The perspective of equality is always present in the development of our future activities. Equality does not mean treating everyone in the same way, but valuing everyone equally while acknowledging the individual needs of each person. Achieving equality may require taking the positive actions referred to in the Non-Discrimination Act. 

This plan is also based on the DPDSA’s values: courage, appreciation, and trust. We at the DPDSA want to boldly develop our services to serve our customers better and prove that we value both our customers and personnel, and to ensure the reliability of our operations and services. The measures of this plan will be implemented as part of the DPDSA’s usual daily activities.

The DPDSA employs more than 900 people and operates in more than 30 locations across Finland. We operate nationally so citizens can use our services at any of our customer service points. Our operating models are the same everywhere, with no local differences in our activities. In our operations, we value diversity, we have respectful conversations and we nurture competence. All our operations are guided by mutual trust and a constant will to improve. We strive to constantly evaluate ourselves and our activities, to ensure that we never stop improving.

Our operations are customer-oriented and we want to produce a positive customer experience. When developing our services, we always take into account changes in the operating environment and their impact on our clients' requirements and expectations. We help our customers manage their affairs as smoothly as possible and find the best solutions for their own needs. We treat our customers equally and respectfully.

We provide reliable services that meet customer needs and are cost-effective. The services are produced in accordance with the principles of sustainable development. We contribute to good governance. As part of public administration, we are committed to building the preconditions for a good life for everyone.

The DPDSA has several completed and on-going development projects that aim to improve the efficiency and customer-friendliness of our agency’s services. These projects have placed particular emphasis on the diverse and varied needs of our customers, for example by improving the accessibility of Suomi.fi services. As an example, the Mona project – which focuses on the DPDSA’s multi-channel service chain and customer service approach – aims to improve the availability of customer services, in-crease the use of electronic services, and create a common, DPDSA-wide customer policy. The Agency also makes use of premises projects to ensure the accessibility of its new premises.   
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According to section 17 of the Constitution, the national languages of Finland are Finnish and Swedish. The linguistic rights of Sámi, Romani, and sign language speakers are also safeguarded by legislation. Finnish authorities must proactively ensure that the linguistic rights of private individuals are implemented in practice.

The starting point for our customer service is to ensure a genuine level of interaction and understanding between our customers and employees. Having a common language is a prerequisite for interaction, and this applies to Finnish, Swedish, Sámi, Romanian, foreign languages, and sign language, as well as any communication methods that are used in place of speech. Many of the customers who visit our service locations often have their own interpreters, to ensure a mutual level of understanding.

The “Kielelliset oikeudet” (Linguistic rights) eOppiva online course is a mandatory part of the orientation provided to all new DPDSA employees. The course provides a primer on the basics of linguistic rights and how they should be taken into account in different situations. In addition, we have developed and maintained our employees’ language skills by offering several Swedish and English language courses for learners of all skill levels. We will continue to develop our versatile language proficiency in the future as well, as we have recognised the role that language plays in fostering equality and enhancing our daily activities. 

Section 9 of the Administrative Procedure Act obliges Finnish authorities to use appropriate, clear, and understandable language. Since the DPDSA’s customer base includes virtually all Finnish citizens and persons living in Finland, our customers must be able to understand the language we use. Clear, even plain language is a necessity for many people, such as immigrants who are still learning Finnish, certain disability groups, and the elderly. 

The DPDSA’s central communication channel is its website, dvv.fi. Both the structure and contents of the website have been revised and clarified in recent years. All new texts on our website have been written in accordance with the principles of clear official language and, where appropriate, the principles of plain language. When our service experts write new texts, they always consult a Finnish language or communications expert to ensure that their output is customer-friendly and generally comprehensible to all customers. 

Our website also strives to take different language groups into account. We treat both Finnish and Swedish equally, and all the written content on our website is available in both languages. In addition to Finnish and Swedish, we have translated most of our pages into English, to allow people from other language groups to find the information they need. A few key forms are also available in Northern Sámi, French, and Russian, based on estimated customer demand.

In addition to our own website, we maintain the suomi.fi website. Its key objective is equality, to allow everyone to use its services without discrimination while understanding their contents. In particular, the Suomi.fi guides that we have produced on different topics have been praised for their clarity and informativeness. The contents of the Su-omi.fi website are available in Finnish, Swedish, English, and sign language. 

In addition to the website, we also strive to communicate clearly in our other communication channels as well as in, for example, our daily customer communications and service encounters. To support these goals, over the past year we have arranged training sessions on clear language and writing for DPDSA personnel, and we intend to continue these efforts. In addition, we have sought to strengthen our personnel’s language awareness and writing skills with weekly linguistic tips. Our motto is that each of our employees is also a communicator, which means that it is imperative for everyone to pay attention to how they communicate. 

Future measures: 

• We will continue to clarify the language used by the Agency. 
• We will consider producing plain language material. 
• We will improve the comprehensibility of our customer letters as well as our web-sites and online services. 
• If necessary, we will investigate the procurement of interpretation services.

Our accessibility requirements are based on the European Union’s Accessibility Directive and the United Nations Convention on the Rights of Persons with Disabilities to act in a digital environment. The requirements of the Directive have been implemented in Finland with the Act on the Provision of Digital Services (306/2019). In practice, the Act mandates compliance with international accessibility criteria (WCAG). The Accessibility Directive defines the minimum requirements for the accessibility of online services and mobile applications provided by public administration, and it also aims to en-sure that online public and municipal services remain available to all citizens. 

The DPDSA’s services are intended for everyone, which is why the starting point for its planning and development activities is always optimal accessibility for each user. Our goal is to allow as many people as possible to use the digital services we provide. In addition to online services, we will always offer an alternative service channel to our customers. 

In this context, digital services refer to our external and internal websites (dvv.fi, suo-mi.fi, the Divi-intranet), as well as the various online services we provide to our customers. An accessible service consists of a technical implementation that complies with the necessary requirements, a well-designed user interface, and a comprehensible selection of contents. 

At the moment, some of our digital services do not meet all of the requirement set forth in the EU’s accessibility criteria, and there are differences between their technical implementations. However, we have carried out various accessibility audits and made use of their results as part of the continuous development of our services. We have also prepared separate accessibility statements for each of our online services. These statements take into account the equal accessibility of digital services and provide more detailed information on any possible shortcomings and how they have been fixed. At the DPDSA, accessibility is an important criterion for all new services that are still under development, and it is also a key part of their technical implementation and content production process. 

Our goal is to ensure that everyone at the DPDSA is aware of at least the basics of accessibility, which is why our employees are required to participate in eOppiva’s accessibility training. 

Future measures:

• Accessibility audits of current services and the resulting corrective measures will be made part of the continuous improvement process. Accessibility reviews will be made into a continuous activity.
• Ensuring accessibility will become part of the implementation process for new services.
• Personnel will be instructed on accessibility.

National operating models and procedures are essential for ensuring that our customer service remains both equal and non-discriminatory.

The DPDSA’s customer service serves as the face of the entire Agency. We will con-tinue to develop our customer service and customer expertise, to ensure the quality and equality of the service we provide.

We promote the equality of our customers in our customer service in the following ways:

• We provide our services through different channels. Our customers are free to choose the customer channels that suit them best. We take customer equality and demand into account in the development of our service channels and their opening hours.
• We monitor the quality of our customer service through regular customer satisfac-tion surveys.
• We take the demand for our services into account in the allocation of our re-sources, and we react to any possible changes in demand.
• We ensure that our approach to customer service remains consistent across Fin-land.
• We take current issues into account in our customer communications and strive to increase our customers’ awareness of our services.
• We develop our services by collecting data on customer experiences.Future measures:
• We will regularly review our service channels and their contents to ensure a pleas-ant customer experience.
• We will continuously develop our electronic customer service channels and im-prove their availability.
• We will actively involve our customer service personnel in the development of their own work.
• We will develop our joint service points together with other authorities.
• We will continuously develop and maintain the expertise of our customer service personnel.

Under section 8 of the Administrative Procedure Act (434/2003), an authority shall, within its competence, provide its customers, as necessary, with advice on dealing with administrative matters and respond to questions and enquiries concerning the use of its services. Customers must receive the services they are entitled to. This also applies to electronic services, as the Act on the Provision of Digital Services (306/2019) obliges authorities to offer digital service channels. 

The DPDSA provides digital support by assisting its customers in the use of its online offerings. We help our customers use our electronic services independently and safely. The DPDSA includes a Digital Support service that is responsible for developing digital support policies nationally. The Digital Support service trains and supports digital sup-port providers, studies digital competence phenomena and develops digital support operating models together with digital support actors. 

Future measures:

• The digital support models and materials collected by the Digital Support service will be utilised in the DPDSA’s own services.  
• We will ensure that our customer service personnel are trained in the provision of digital support. 
• We will continue to collect customer feedback and use it to develop our services more efficiently 

The DPDSA aims to make its customer service facilities as physically accessible as possible for all users. The DPDSA takes the necessary requirements for physical accessibility into account in the planning and implementation of its premises and work environments.  The planning of the DPDSA’s customer service facilities is guided by, for example, the Government Decree on the Accessibility of Buildings and the Ministry of Finance’s concept for shared work environments, especially with regard to the Agency's customer service. 

Principles guiding compliance with physical accessibility requirements: 

• The elements of a space, such as its surface materials, furnishings, and guidance materials, must pay attention to customers with physical and sensory limitations and those who speak other languages.
• Differences in level and thresholds are to be avoided in all spaces. The dimensions of customer service points must take into account both wheelchair users and people of different sizes.
• At least one service facility in the premises, as well as essential support facilities (including toilet facilities), must be accessible.
• All accessible toilets are to be placed in connection with waiting areas. 
• The customer service area must be equipped with an induction loop to allow customers who use hearing aids to better hear the customer expert’s speech. 
• Any digital user interfaces located in customer service areas must be accessible, intuitive, and easy to use.  
• When necessary, interpretation solutions must be taken into account in service situations. 

The DPDSA has several offices around Finland. Different locations have different physical prerequisites for providing an accessible customer service experience. The DPDSA promotes physical accessibility by centralising its on-location customer services to joint public administration customer service points.

All forms of discrimination and other inappropriate treatment are strictly prohibited at the DPDSA, and they are addressed immediately. All customer feedback that details any harassment, discrimination, or inappropriate treatment experienced by customers will be investigated and addressed.

The DPDSA’s primary approach is to prevent problematic behaviour by providing a thorough orientation process and clear operating models, as well as by arranging early interventions in the event of any problematic situations. The operating models for dealing with problematic behaviour are described in the Peace at Work Package prepared by the DPDSA. More detailed instructions are available in the instructions on preventing and addressing harassment and other inappropriate and undesirable behaviour.

The equality plan for customers is updated every two years. The implementation of the equality plan for customers and the measures for promoting it will be evaluated systematically, by examining how the measures and objectives presented in the equality plan have been implemented. 

Key development measures: 

1. We will use the customer service development project to describe how the DPDSA should handle its customer encounters, and we will continuously train our personnel.
2. We will make more extensive use of customer feedback and the results of custom-er satisfaction surveys. Our customer surveys will take the perspective of equality into account. 
3. We will continue to improve our websites and materials with a particular focus on language planning and plain language. 
4. We will provide our personnel with continuous training on equality and accessibility.
5. We will strengthen our personnel’s ability to provide digital support for the DPD-SA’s own services.