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 The Administrative Court repealed the Data Protection Ombudsman’s decision and found that patient records from medical appointments are, as a general rule, essential in establishing causality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.

eQ Community Properties Fund – Sale of seven social infrastructure properties

We are assisting eQ Community Properties Fund in the sale of seven social infrastructure properties to Kinland AS. The value of the transaction is approximately EUR 29 million, and the portfolio comprises three preschool facilities and four child protection units from different parts of Finland. The portfolio consists of modern and energy-efficient properties that are long-term leased to leading operators in the industry. The Weighted Average Unexpired Lease Term (WAULT) is approximately 11 years. The transaction is expected to close on 17 December 2025.

Ålandsbanken – Consent solicitation process regarding T2 instruments and issue of SEK 350 million AT1 notes

We advised Ålandsbanken Abp in the consent solicitation process regarding its SEK 150,000,000 Tier 2 notes due December 2041 and SEK 200,000,000 Tier 2 notes due March 2043. The terms and conditions of the aforementioned instruments were amended by removing the write-down mechanisms in the consent solicitation process. In addition, we advised Ålandsbanken Abp on the issue of SEK 350 million Additional Tier 1 notes. The notes bear floating interest at the rate of STIBOR three months plus a margin of 3.35 per cent per annum. The AT1 notes were issued on 20 November 2025, and admitted to trading on the official list of Nasdaq Helsinki Ltd. The instrument has no maturity date and qualifies as Additional Tier 1 capital in accordance with the EU Capital Requirements Regulation. The issue strengthens Ålandsbanken’s capital structure by taking advantage of favourable market conditions.

SuperOffice – Acquisition of Lyyti

We acted as Finnish counsel to SuperOffice AS, backed by Axcel, in its acquisition of Lyyti Oy from Finnish private equity firm Vaaka Partners and other sellers. Lyyti is a leading event management software company for physical, digital and hybrid events with a strong customer base in Finland, Sweden and France. SuperOffice is a leading provider of customer relationship management (CRM) software for small and medium-sized businesses across Northern Europe. Axcel is a Nordic private equity firm with a focus on technology, business services and industrials, healthcare, and consumer sectors.

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