Regulatory Investigations and Disputes

Regulatory Investigations and Disputes

Disputes relating to data protection and data regulation are on the rise. We offer you a team with a solid experience in authority proceedings and disputes in the field of data protection and regulation.

The increasing value of personal and other data also means that contracting parties are becoming more vigilant in protecting their interests, and people are more aware of their rights with respect to data processing. Sometimes the parties’ interests and rights intersect to such an extent that it is necessary to resort to dispute resolution procedures.

Our highly experienced experts regularly assist clients in administrative, civil and criminal proceedings. We have received a great deal of praise from clients for our efficient and skilled handling of proceedings and our wide range of expertise and understanding of regulation, technology and business.

Latest references

Finnish Motor Insurers’ Centre – Precedent concerning patient data processing and repeal of administrative fine

The Supreme Administrative Court (SAC) issued a significant precedent (decision KHO:2025:23) in a case in which it found that the Finnish Motor Insurers’ Centre (Liikennevakuutuskeskus, LVK) processed patient data in accordance with the requirements concerning fairness, data minimisation, and privacy by design and by default when deciding on compensation claims. We represented LVK in this case in which the SAC upheld the Administrative Court’s decision to repeal the EUR 52,000 administrative fine imposed on LVK by the Sanctions Board of the Office of the Data Protection Ombudsman. The SAC also confirmed the Administrative Court’s decision, which, as far as we know, was the first of its kind in Finland, ordering the Office of the Data Protection Ombudsman to reimburse some of our client’s legal costs. The decision bears great significance for the insurance industry as a whole. The crux of the matter were LVK’s information requests under the Motor Liability Insurance Act for patient data that were essential in determining insurance or compensation claims. In certain cases, making a decision may require extensive patient data. The Office of the Data Protection Ombudsman had found that LVK had systematically made overly broad information requests infringing Articles 5 and 25 of the GDPR and that the information should have been provided in the form of separate medical opinions. The Administrative Court repealed the Data Protection Ombudsman’s decision and found that patient records from medical appointments are, as a general rule, essential in establishing causality in compensation matters. It also stated that the tasks related to the consideration of compensation matters are specifically the core tasks of the insurance company and not of the controller of patient data. Furthermore, the Administrative Court found no evidence indicating that LVK would have systematically made overly broad information requests. ‘Once again, our collaboration with C&S was seamless throughout this extensive process, and we could trust that our case was in expert hands’, says Visa Kronbäck, Chief Legal Officer of the Insurance Centre. The full decision is available on the SAC website (in Finnish): KHO:2025:23.

Urban Partners – Financing of EUR 100 million construction project in Herttoniemi, Helsinki

We advised the real estate investor and developer Urban Partners in the financing of a EUR 100 million construction project in Helsinki, which combines build-to-rent housing and care homes within one scheme. A fund managed by Urban Partners (NSF V) purchased the plot of land in Herttoniemi, Helsinki and subsequently secured planning consent to deliver a hybrid living scheme. The modern complex will offer high-quality housing and care facilities for the elderly alongside rental accommodation. A total of 425 apartments and 108 care homes will be delivered across four buildings on the site. The project will be implemented in accordance with Urban Partners’ sustainability targets. All buildings will be constructed to energy class A, and the project will aim for the highest Platinum level of the international LEED environmental certification and will be implemented in accordance with the EU taxonomy criteria.

Citycon – Sale of a 275-apartment residential portfolio

We assisted Citycon Oyj in the sale of the Lippulaiva residential assets in Espoo, Finland. The sold residential assets consist of 275 apartments totaling approximately 13,000 sqm, located in connection to Citycon’s Lippulaiva shopping centre. The assets were sold at their latest IFRS book value for a gross purchase price of EUR 61.5 million.

S-Bank – Issuance of EUR 150 million SNP notes and tender offer for notes maturing in 2026

We advised S-Bank Plc in its issuance of a EUR 150 million Senior Non-Preferred Notes and on the tender offer of its EUR 150 million Senior Preferred MREL Eligible Notes maturing in 2026. The tender offer required prior approval from the Finnish Financial Stability Authority based on the Commission’s regulatory technical standards (EU) 2023/827. The Stability Authority granted S-Bank a permission for repurchases of the notes. Based on the permission, S-Bank replaced the notes with own funds or eligible liabilities instruments of equal or higher quality at terms that are sustainable for the income capacity of S-Bank. According to the final tender offer results published on 10 December 2025, S-Bank repurchased a total of EUR 97.9 million of the notes. The new notes will pay a floating interest rate, which is determined based on 3-month Euribor added with a margin of 1.35 per cent. The notes were issued on 11 December 2025 and listed on Nasdaq Helsinki Ltd. The maturity date of the notes is 11 December 2029. The purpose of the issue was to meet the minimum requirement for own funds and eligible liabilities (MREL) and to finance the bank’s activities.

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