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Privacy Policy for the John Nurminen Foundation Group’s customer and supporter register
Privacy Policy for the John Nurminen Foundation’s stakeholder register
Privacy Policy for the John Nurminen Foundation’s Recruitment and manuscript filing system 
Cookie policy of the John Nurminen Foundation

Privacy Policy for the John Nurminen Foundation Group’s customer and supporter register

This privacy policy (hereinafter the “Privacy Policy”) for the John Nurminen Foundation and its subsidiary Baltic Sea Services Oy’s (“JNS” or “we”) customer and supporter register was created on 24 May 2018 and was last updated on 10 May 2023. The updates are described in more detail in Section 12. Amendments to the Privacy Policy

In this Privacy Policy, we provide a detailed description of how JNS collects and processes the personal data of contact persons for our customers, donors and other supporters, and of employees working with our potential customers’ and partners’ sponsorship and sustainability issues. You can also find more information about your rights with regard to the processing of your personal data.

JNS respects your privacy and is committed to processing your personal data in an appropriate manner in compliance with both this Privacy Policy and the European Union’s (“EU”) General Data Protection Regulation (2016/679) and other applicable legislation (together “Data Protection Legislation”).

1. Controller

The John Nurminen Foundation is the controller of any data processing described in this policy that is not related to book and product sales or e-commerce:

John Nurminen Foundation
Pasilankatu 2
00240 Helsinki, Finland

Baltic Sea Services Oy, a subsidiary of the John Nurminen Foundation, is the controller of data processing that relates to book and product sales and e-commerce:
Baltic Sea Services Oy
Pasilankatu 2
00240 Helsinki, Finland
myynti(a)balticseaservices.fi

2. Contact person

Anni Kujala
Pasilankatu 2
00240 Helsinki
rekisteri(a)jnfoundation.fi
+358 50 467 6740

3. Name of the register

John Nurminen Foundation and Baltic Sea Services Oy customer and supporter register

4. The purpose of and legal basis for processing your personal data

We process personal data for the purposes described below, such as managing and developing customer, donor or supporter relations, and for targeting our communications and marketing to both private persons and communities and their contact persons. We collect only the personal data that is necessary in relation to the purposes for which it is being processed.

The purpose of processing your personal data is:
– Carrying out and managing an agreement, for example, when you order products from JNS’s webstore
– Product delivery, invoicing and debt collection
– Customer service
– Managing monthly and other donations, and fulfilling accounting obligations
– Publishing the information you wish to appear in the donor register
– Sending supporter reports and other communications about the use of donation funds
– Sending information to collection organisers about the total amount collected and the donors who participated in commemorative and anniversary collections
– Developing our activities and customer experience
– Designing and developing our products and services
– Organising events
– Collecting feedback
– Sending information about JNS’s ongoing projects
– Organising promotional prize draws and competitions, and their associated communications
– Customer acquisition, direct marketing and marketing communications for the purpose of acquiring donations

Customer relationship management

The legal basis for processing personal data for customer relationship management, managing donor and supporter relations, and keeping in contact with partners is either JNS’s legitimate interest or to enable JNS to implement agreements.

In connection with customer relationship management, the primary purpose of processing personal data is to carry out business transactions between the customer and JNS, for example, when you make a donation or order products from the Foundation’s online store. Personal data can be processed for purposes such as invoicing, customer service, product delivery or collecting overdue invoices.

In connection with the management of donor and partner relations, we also process personal data for publishing the information specified by the donor in a public donor register or providing information about how donations have been used.

Competitions and prize draws

Within the framework of our activities, we organise a variety of competitions and prize draws on our website, in our communication channels (such as social media) and on our partners’ premises. In this case, the legal basis for the processing of your personal data is JNS’s legitimate interest in running promotional prize draws and/or competitions, and sending associated communications or carrying out other related activities after you have entered a competition or prize draw arranged by us, or when you have given us your permission to publish content submitted at exhibitions, on our website, or in another of our communication channels (including social media). When you enter a prize draw, we may ask for your consent to direct digital marketing.

Direct marketing

We may process your personal data for direct marketing purposes and to target marketing, in which case the legal basis for processing data is JNS’s legitimate interest. In this case, we may contact you by phone or letter in order to market things such as fundraisers or activities. You have the right to prohibit the processing of your personal data for direct marketing purposes at any time.

Direct digital marketing

We process your personal data for direct digital marketing with your consent. In this case, we may contact you by email in order to market things such as fundraisers or activities. Our direct digital marketing also includes our newsletter, which contains information about progress on JNS’s projects and other current topics that we believe will be of interest to you.

We may also send direct digital marketing on the basis of an earlier customer relationship or an authorisation based on your position. In this case, the legal basis for processing your personal data is JNS’s legitimate interest.

Based on our legitimate interest, your personal data may also be used for profiling, for example, for marketing purposes. JNS does not make any automated decisions that would have legal implications.

At any time, you have the right to object to the processing of your personal data for the purposes of direct marketing or profiling for direct marketing.

We also use cookies and other similar technologies on our website and in our newsletters, to ensure the functionality of our website, to develop and improve our user experience, and to target relevant marketing. You can read more about the cookies we use, their purpose and retention periods in our Cookie Policy.

5. What personal data do we collect and from where?

We collect the following personal data in our customer and supporter register:
– person’s name
– age/year of birth
– position and company/organisation
– contact details (such as address, email address and telephone number)
– the start and end time of the customer relationship and/or other contact, and the contact method
– invoicing details and payments
– customer history, notes about the customer relationship and notes about meetings
– donation information and information required to process bequests
– school and grade in connection with our Taksvärkki collection
– information about subscription to the newsletter mailing list
– information about consent to/prohibition of direct marketing
– other information necessary for organising and developing events, such as dietary requirements and restrictions
– other information necessary for a competition or prize draw, such as a photo submitted by a competition or prize draw entrant and the name of the photographer
– any other information necessary for accepting donations, customer account management and partnerships.

As a rule, we mainly collect data for the customer and supporter register from you yourself, for example, when you give us information via online forms or social media services, by email or telephone, in agreements, via event registrations and payment information, when entering a competition or prize draw, and at customer meetings or other events at which you disclose your information.

Personal data may also be collected from public sources or from companies that provide services for updating and obtaining personal data. These include Posti’s consumer register update service, Suomen Asiakastieto Oy’s decision-maker register and Profinder’s corporate and consumer information registers.

In addition, we collect personal information using cookies and other similar technologies on our website and in our newsletters.

6. Will your personal data be disclosed or transferred to third parties?

We only transfer your personal data when it is necessary to carry out one of the aforementioned purposes. JNS may transfer your personal data to parties involved in the provision, maintenance and development of JNS’s services, communications and marketing, or to its other partners, and these parties may process your personal data for the purposes described in this Privacy Policy.

Our partners for customer service and marketing include Sanoma Media Finland Oy, Barona Oy, Gainer Oy and LiveRing Oy. Your data may also be transferred to other subcontractors and service providers that are responsible for IT, software, accounting and other similar services. JNS will enter into the necessary contractual arrangements with third parties to ensure that your personal data is processed in accordance with Data Protection Legislation.

If you make a donation to a commemorative or anniversary collection, we will send your name to the collection organiser. Your personal data may also be disclosed to third parties in certain situations, such as those in which its disclosure is required by law or official regulations.

Please note that third parties may process the information collected via cookies and social media plugins on our website.

JNS or its service providers may use companies located outside the EU or European Economic Area (“EEA”) to process personal data or provide services. Personal data will only be transferred out of the EU or EEA when there are justified grounds for doing so and in compliance with Data Protection Legislation.

7. Joint controllers

When JNS administers pages on Facebook and Instagram, JNS and Meta Platforms Ireland Ltd (“Facebook”) are the joint controllers of JNS’s Facebook and Instagram pages, as applicable. Your personal data will be used for purposes such as keeping you informed about JNS’s work/events and how donations have been used; running competitions and prize draws; marketing and collecting feedback; purchasing and measuring the performance of Facebook advertisements; and better targeting communications. The legal basis for processing your personal data is JNS’s legitimate interest.

JNS collects data through its Facebook and Instagram pages in the form of, for example, likes and other reactions, comments, visits, post visibility, and personal data submitted in connection with competitions. The information that JNS receives from Facebook is the person’s user name, public profile picture, and any other data that has been marked as public. Data subjects may provide other personal data in comments on social media pages or via messaging services.

Where applicable, we are also joint controllers with Facebook with respect to the cookies used in Facebook’s social media plugins and certain services relating to Facebook’s advertising networks. You can read more about cookies and social media plugins in our Cookie Policy.

In Facebook’s privacy policy, you can read how and on what legal basis Facebook processes your data, and how you can exercise your rights under data protection legislation. We have signed a joint controller agreement with Facebook that describes JNS’s and Facebook’s responsibilities with respect to the data we collect. Please note that if you wish to exercise your rights under data protection legislation with respect to data processed by Facebook, you should contact Facebook.

You can restrict the processing of your personal data by unliking and/or unfollowing a page. You can also request a conversation to be deleted from a messaging service. You can also choose not to accept non-essential cookies when you visit our website, or withdraw your previously given consent.

8. How is your personal data processed and protected?

JNS processes your personal data only for the aforementioned purposes and only for the purposes for which the data was originally collected. The protection of your personal data is important to us, and we comply with both good data management practices and the due diligence and obligations laid down in Data Protection Legislation. We adhere to generally accepted technical and organisational measures to prevent any unauthorised or unlawful processing or misuse of personal data, and to protect personal data from loss, alteration or deletion. The electronically processed personal data contained in the register is protected by means of firewalls, passwords and other technical means that are generally used and accepted in the information security industry. Workstations and IT systems are protected using personal usernames and passwords. Our workstations also utilise two-factor authentication. Manually maintained material is located in facilities to which unauthorised access is prevented. Access to the personal data contained in the register is granted only to designated employees of the Foundation or of an enterprise acting for or on behalf of the Foundation, and only to the extent that is required to carry out the task at hand. Our employees have signed a non-disclosure agreement.

9. For how long will your personal data be retained?

We comply with statutory retention periods, and will retain your personal data only for as long as is necessary, and to the extent that is required, to carry out the purposes for which the personal data is being processed as defined in this Privacy Policy (for example, for the duration of a contractual term).

10. What are your rights as a data subject?

As a data subject, you have the following rights with regard to your personal data in the customer and supporter register:

– The right to access and verify your data: You have the right to receive confirmation from us about whether or not your personal data is being processed; and if your personal data is being processed, you have the right to access and verify all of the personal data being held about you in the customer and supporter register.
– The right to correct, delete and restrict the processing of your data: You have the right to require us to correct any inaccurate, unnecessary, incomplete or outdated personal data without undue delay. You have the right to request us to delete any of your personal data that is no longer required for the purpose for which it was originally collected or processed, or if you suspect that your personal data is being processed illegally, or if your personal data must be deleted to comply with a legal obligation (that applies to the controller). You also have the right to request a restriction on the processing of your data. Please note that deleting or restricting the use of your personal data may, for instance, result in a deterioration in your customer service experience, that you can no longer be a monthly donor, or that you no longer receive our newsletters or information on our project progress.
– The right to object to the processing of your data: When the basis for processing personal data is JNS’s legitimate interest, you have the right to object to the processing of your personal data with respect to a specific personal situation. The exception to this is when JNS can demonstrate that there is a very important and justified reason that overrides the data subject’s interests, or if processing is necessary for the preparation, presentation or defence of a legal claim. However, you always have the right to object to the processing of your personal data for direct marketing purposes (including profiling) without any justification. Please note that objecting to the processing of your personal data may, for instance, result in a deterioration in your customer service experience, that you can no longer be a monthly donor, or that you no longer receive our newsletters or information on our project progress.
– The right to transfer data from one system to another: You have the right to transfer the personal data you supplied to JNS to another controller. This transfer right covers automatically processed personal data whose processing is based on your consent or an agreement to which you are a party. JNS will send the data in a machine-readable and commonly used format to you, and will also send the data directly to the other controller if this is technically possible.
– The right to withdraw consent: If your personal data is being processed on the basis of your consent, you may withdraw your consent to such processing at any time by contacting us.

If you would like to exercise any of the rights described above, would like to receive more information about the processing of your personal data, or have any comments on its processing, you can contact us at any time by sending an email to rekisteri(a)jnfoundation.fi.

11. Lodging a complaint with the supervisory authority

JNS always aims to resolve any disputes regarding the processing of your personal data directly with you. If you believe that JNS has not processed your personal data in accordance with applicable Data Protection Legislation, you have the right to lodge a complaint with the competent supervisory authority. The contact details for the supervisory authority are:

Office of the Data Protection Ombudsman
P.O. Box 800
00531 HELSINKI
Visiting address: Lintulahdenkuja 4, 00530 Helsinki
email: tietosuoja@om.fi
telephone exchange: +358 (0)29 56 66700
www.tietosuoja.fi.

12. Amendments to the Privacy Policy

We continuously strive to develop our services and privacy protection, and therefore reserve the right to change this Privacy Policy by placing a notification of change on this page. The Privacy Policy may also be updated in order to reflect changes in legislation. We recommend that you revisit this Privacy Policy on a regular basis.

The following updates have been made to this Privacy Policy:

– Update 30 November 2021 We revised and clarified the purposes of processing personal data, and added that we may also collect personal data from public sources.
– Update 31 January 2023 We added that personal data may also be collected from companies that provide services for updating and obtaining personal data.
– Update 10 May 2023 We combined the privacy policies for our customer and supporter register and our competitions and prize draws register, and the name of the document was changed to the “Privacy policy for the John Nurminen Foundation Group’s customer and supporter register”. We clarified from which public sources personal data is obtained, and to whom our customer service and marketing partners may disclose personal data.

Privacy Policy for the John Nurminen Foundation’s stakeholder register

This privacy policy (hereinafter the “Privacy Policy”) for the John Nurminen Foundation’s (“JNS” or “we”) stakeholder register was created on 29 May 2018 and updated on 30 November 2021. In this Privacy Policy, we provide a detailed description of how JNS collects and processes the personal data of representatives of our various stakeholders. You can also find more information about your rights with regard to the processing of your personal data.

JNS respects your privacy and is committed to processing your personal data in an appropriate manner in compliance with both this Privacy Policy and the European Union’s (“EU”) General Data Protection Regulation (2016/679) and other applicable legislation (together “Data Protection Legislation”).

1. Controller

John Nurminen Foundation
Pasilankatu 2
00240 Helsinki, Finland
info(a)jnfoundation.fi

2. Contact person for the privacy policy and person responsible for data protection

Anni Kujala
Pasilankatu 2
00240 Helsinki
rekisteri(a)jnfoundation.fi
+358 50 467 6740

3. Name of the register

John Nurminen Foundation stakeholder register

4. The purpose of and legal basis for processing your personal data

We process personal data in order to manage and develop communications and collaborative partnerships with, for example, the contact persons for our project partners, government ministries, authorities and service providers, media representatives, Baltic Sea Action Day partners, as well as members of steering groups appointed to our projects. In order to acquire new partners for sustainability projects, JNS may also reach out to employees of potential partner companies whose responsibilities include stakeholder engagement, sponsorship, or sustainability issues. We collect only the personal data that is necessary in relation to the purposes for which it is being processed. The purpose of processing your personal data is:

– Sending information about JNS’s ongoing projects
– Keeping you informed about JNS’s activities
– Sending out press releases and media invitations
– Convening steering group meetings
– Sending invitations to JNS’s events and meetings
– Managing other collaborator and stakeholder relations
– Managing Baltic Sea Action Day events, activities and other contacts
– Contacting new and potential partners and partner companies.

The legal basis for processing stakeholders’ personal data is JNS’s legitimate interest and to enable JNS to implement agreements. JNS does not make any automated decisions that would have legal implications.

We may also process data about employees of our stakeholder organisations for direct marketing purposes. Our direct marketing mainly covers our newsletter, which is sent either by email or post, and contains information about progress on JNS’s projects and other current topics that we believe will be of interest to our stakeholders and their employees. The Foundation’s newsletter is only sent to those people who have subscribed to it. Consent is the basis for processing personal data in this context. You have the right to prohibit the processing of your personal data for direct marketing purposes at any time.

We also use cookies and other similar technologies on our website and in our newsletters, to ensure the functionality of our website, to develop and improve our user experience, and to target relevant marketing. You can read more about the cookies we use, their purpose and retention periods in our Cookie Policy.

5. What personal data do we collect and from where?

We collect the following personal data in our stakeholder register:

– person’s name
– position and company/organisation
– contact details (such as address, email address and telephone number)
– information about consent to/prohibition of direct marketing
– information about subscription to the newsletter mailing list
– the start and end time of the contact, and the contact method
– notes about the stakeholder relationship and notes about meetings
– any other necessary information relating to cooperation
– any other information necessary for organising and developing events, such as dietary requirements and restrictions.

As a rule, we mainly collect data for the stakeholder register from you yourself, for example, when you give us information via online forms or social media services, by email or telephone, in agreements, or during meetings and other events at which stakeholders disclose information. We may also collect personal data from public sources and, for non-commercial purposes, from third parties on the basis of, for instance, recommendations.

In addition, we collect personal information using cookies and other similar technologies on our website and in our newsletters.

6. Will your personal data be disclosed or transferred to third parties?

We only transfer your personal data when it is necessary to carry out one of the aforementioned purposes.

JNS may transfer your personal data to parties involved in the provision, maintenance and development of JNS’s services and communications, or to its other partners, and these parties may process your personal data for the purposes described in this Privacy Policy. Your data may also be transferred to other subcontractors and service providers that are responsible for IT and other similar services. JNS will enter into the necessary contractual arrangements with third parties to ensure that your personal data is processed in accordance with Data Protection Legislation.

In principle, your personal data will not be disclosed to third parties without your consent. However, your personal data may be disclosed to third parties without your consent in some situations, such as situations in which its disclosure is required by law or official regulations. If necessary, we may also provide funding organisations, such as the European Union, with lists of event participants, so that the funders can confirm that a project’s objectives have been realised and fulfil their legal obligations.
Please note that third parties may process the information collected via cookies and social media plugins on our website.

JNS or its service providers may use companies located outside the EU or European Economic Area (“EEA”) to process personal data or provide services. Personal data will only be transferred out of the EU or EEA when there are justified grounds for doing so and in compliance with Data Protection Legislation.

7. Joint controllers

When JNS administers pages on Facebook and Instagram, JNS and Facebook Ireland Ltd (“Facebook”) are the joint controllers of JNS’s Facebook and Instagram pages, as applicable. Your personal data will be used for purposes such as keeping you informed about JNS’s work/events and how donations have been used; running competitions and prize draws; marketing and collecting feedback; purchasing and measuring the performance of Facebook advertisements; and better targeting communications. The legal basis for processing your personal data is JNS’s legitimate interest. Data used in competitions will be processed in accordance with a separate privacy policy that will be issued for each competition.
JNS collects data through its Facebook and Instagram pages in the form of, for example, likes and other reactions, comments, visits, post visibility, and personal data submitted in connection with competitions. The information that JNS receives from Facebook is the person’s user name, public profile picture, and any other data that has been marked as public. Data subjects may provide other personal data in comments on social media pages or via messaging services. This information will not be combined with other data held in personal data registers without informing the data subject or without the data subject’s consent.

Where applicable, we are also joint controllers with Facebook with respect to the cookies used in Facebook’s social media plugins and certain services relating to Facebook’s advertising networks. You can read more about cookies and social media plugins in our Cookie Policy.

In Facebook’s privacy policy, you can read how and on what legal basis Facebook processes your data, and how you can exercise your rights under data protection legislation. We have signed a joint controller agreement with Facebook that describes JNS’s and Facebook’s responsibilities with respect to the data we collect. Please note that if you wish to exercise your rights under data protection legislation with respect to data processed by Facebook, you should contact Facebook. You can restrict the processing of your personal data by unliking and/or unfollowing a page. You can also request a conversation to be deleted from a messaging service. You can also choose not to accept non-essential cookies when you visit our website, or withdraw your previously given consent.

8. How is your personal data processed and protected?

JNS processes your personal data only for the aforementioned purposes and only for the purposes for which the data was originally collected. The protection of your personal data is important to us, and we comply with both good data management practices and the due diligence and obligations laid down in Data Protection Legislation. We adhere to generally accepted technical and organisational measures to prevent any unauthorised or unlawful processing or misuse of personal data, and to protect personal data from loss, alteration or deletion. The electronically processed personal data contained in the register is protected by means of firewalls, passwords and other technical means that are generally used and accepted in the information security industry. Workstations and IT systems are protected using personal usernames and passwords. Our workstations also utilise two-factor authentication. Manually maintained material is located in facilities to which unauthorised access is prevented. Access to the personal data contained in the register is granted only to designated employees of the Foundation or of an enterprise acting for or on behalf of the Foundation, and only to the extent that is required to carry out the task at hand.

9. For how long will your personal data be retained?

We comply with statutory retention periods, and will retain your personal data only for as long as is necessary, and to the extent that is required, to carry out the purposes for which the personal data is being processed as defined in this Privacy Policy (for example, for the duration of a contractual term).

10. What are your rights as a data subject?

As a data subject, you have the following rights with regard to your personal data in the stakeholder register:

– The right to access and verify your data: You have the right to receive confirmation from us about whether or not your personal data is being processed; and if your personal data is being processed, you have the right to access and verify all of the personal data being held about you in the stakeholder register.
– The right to correct, delete and restrict the processing of your data: You have the right to require us to correct any inaccurate, unnecessary, incomplete or outdated personal data without undue delay. You have the right to request us to delete any of your personal data that is no longer required for the purpose for which it was originally collected or processed, or if you suspect that your personal data is being processed illegally, or if your personal data must be deleted to comply with a legal obligation (that applies to the controller). You also have the right to request a restriction on the processing of your data. Please note that deleting or restricting the use of your personal data may, for instance, result in you no longer receiving our newsletters or invitations to our events.
– The right to object to the processing of your data: When the basis for processing personal data is JNS’s legitimate interest, you have the right to object to the processing of your personal data with respect to a specific personal situation. The exception to this is when JNS can demonstrate that there is a very important and justified reason that overrides the data subject’s interests, or if processing is necessary for the preparation, presentation or defence of a legal claim. However, you always have the right to object to the processing of your personal data for direct marketing purposes without any justification. Please note that an objection to the processing of your personal data may, for instance, result in you no longer receiving our newsletters or invitations to our events.
– The right to transfer data from one system to another: You have the right to transfer the personal data you supplied to JNS to another controller. This transfer right covers automatically processed personal data whose processing is based on your consent or an agreement to which you are a party. JNS will send the data in a machine-readable and commonly used format to you, and will also send the data directly to the other controller if this is technically possible.
– The right to withdraw consent: If your personal data is being processed on the basis of your consent, you may withdraw your consent to such processing at any time by contacting us.

If you would like to exercise any of the rights described above, would like to receive more information about the processing of your personal data, or have any comments on its processing, you can contact us at any time by sending an email to rekisteri(a)jnfoundation.fi.

11. Lodging a complaint with the supervisory authority

JNS always aims to resolve any disputes regarding the processing of your personal data directly with you. If you believe that JNS has not processed your personal data in accordance with applicable Data Protection Legislation, you have the right to lodge a complaint with the competent supervisory authority. The contact details for the supervisory authority are:

Office of the Data Protection Ombudsman
P.O. Box 800
00531 HELSINKI
Visiting address: Lintulahdenkuja 4, 00530 Helsinki
email: tietosuoja@om.fi
telephone exchange: +358 (0)29 56 66700
www.tietosuoja.fi

12. Amendments to the Privacy Policy

We continuously strive to develop our services and privacy protection, and therefore reserve the right to change this Privacy Policy by placing a notification of change on this page. The Privacy Policy may also be updated in order to reflect changes in legislation. We recommend that you revisit this Privacy Policy on a regular basis.

John Nurminen Foundation Recruitment and manuscript filing system 

Following its entry into force on 25 May 2018 the provisions of the EU General Data Protection Regulation are applied to all organisations processing and holding personal data. The key aim of the new Regulation is to strengthen the rights and the conditions for consent of data subjects in relation to the processing of personal data. In this Privacy Statement issued by the John Nurminen Foundation (hereinafter also the Foundation), we describe in detail what personal data we collect and for what purposes personal data are used. The Privacy Statement also provides further information on the rights of data subjects. 

1. Controller

John Nurminen Foundation 
Pasilankatu 2 
00240 Helsinki 
rekisteri(a)jnfoundation.fi 

2. Contact person for the Privacy Statement

Anni Kujala 
Pasilankatu 2 
00240 Helsinki 
rekisteri(a)jnfoundation.fi 
+358 50 467 6740 

3. Name of filing system

John Nurminen Foundation Recruitment and manuscript filing system 

4. For what purposes and on what legal grounds we can use your personal data

We process personal data for the purpose of managing the application process of persons who apply for a position with the John Nurminen Foundation or submit a manuscript for publishing. Furthermore, we can process personal data in connection with diverse statistical purposes in which case personal data is, as a rule, pseudonymised in such a manner that the personal data can no longer be attributed to a specific data subject. 
The collecting of personal data of data subjects is always limited to what is necessary in relation to the purposes for which they are processed.  

Applications for positions 
Personal data is processed for purposes of carrying out and managing recruitment activities, processing applications, assessing the applicant’s suitability, and carrying out communications related to the application and recruitment. The legal basis for the processing of personal data in accordance with the EU General Data Protection Regulation is the legitimate interest pursued by the controller. 

Manuscript submissions 
Personal data is processed for purposes of evaluating and managing the publishing project, reviewing the manuscript and carrying out communications. The legal basis for the processing of personal data in accordance with the EU General Data Protection Regulation is the legitimate interest pursued by the controller.

5. What data are recorded

We may store the following personal data of applicants: Identifiable information such as name, personal identity code, home address, email address, and telephone number.

• Recruitment: Other information, such as education (e.g. name of degree and institution), work experience (e.g. previous employers, position held, duration of employment), language proficiency, possible information pertaining to suitability assessments, position applied for, and other information provided by the applicant.

• Manuscript: Other information, such as education, previous published works, and the manuscript.

6. How long data are retained

We retain personal data only as long as necessary for the processing purposes specified in this Privacy Statement. The retention period may be longer due to the provisions of the Accounting Act or other statutory requirements binding upon us. 

We store open applications for a maximum of 12 months and applications submitted in response to an announced vacancy for a maximum of 6 months. 

7. From what sources personal data are collected

We collect personal data primarily from data subjects themselves by means of the application and a possible interview. We may also obtain information from other sources to the extent permitted by law. In the case of recruitment, this may include data from a third party performing the suitability assessment. In such cases, we will always ask for your consent before collecting your data.

8. Regular destinations of disclosed data and transfer of data outside the EU or EEA

We can transfer personal data to our own filing systems to be processed for the purposes specified in section 4.   

Apart from our own filing systems, personal data are not disclosed or transferred to entities other than those contracted by the Foundation for the production, development or maintenance of services and communications, except in accordance with an agreement, separate explicit consent and/or specific statutory requirements. We can transfer personal data outside the EU or EEA in compliance with the conditions laid down in the provisions of the EU General Data Protection Regulation. 

9. How your personal data are secured

Protection of privacy is paramount for us, and we exercise great care in the processing operations of personal data contained in the filing system. We adhere to generally accepted standards of technology and operational security in order to prevent any unauthorised or unlawful processing or misuse and to protect personal data from loss, alteration or destruction. 

The electronically processed data contained in the filing system are protected by means of firewalls, passwords and other technical means generally accepted in the information security industry. Manually maintained material is located in facilities to which unauthorised access is prevented. Access to the data contained in the filing system is granted only to designated employees of the Foundation or of an enterprise acting for or on behalf of the Foundation. 

10. Your rights as a data subject

In comparison to the provisions of the repealed Data Protection Directive, the rights of data subjects are specified in more detail in the EU General Data Protection Regulation. The Regulation also confers a number of new rights on data subjects. As a data subject, you have the following rights to your personal data held by the Foundation:

a) Right of access to your personal data. You have the right to know whether we are processing your personal data and to review your personal data we may have collected, if any.

b) Right to rectification of inaccurate or incomplete data. If the data are inaccurate, incomplete or imprecise, you have the right to request your personal data to be rectified, e.g. by means of providing a supplementary statement.

c) Right to erasure, i.e. right to be forgotten. You may request your personal data to be erased under the following conditions:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed and there are no overriding legitimate grounds for the retention of your personal data.

• You withdraw your consent on which the processing is based and there is no other legal ground for the processing.

• You object to the processing and there are no overriding legitimate grounds for the processing.

• The personal data have been unlawfully processed.

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Goal

To combat biodiversity loss in the Baltic Sea and increase local biodiversity by restoring common eelgrass meadows in new areas

Schedule

2023-2026

Status

The first seedlings have been planted

Project partners

Metsähallitus, La Fondation de la Mer, MEDSEA Foundation

Location

Finnish, Italian and French marine areas

Common eelgrass forms dense meadows on the seabed. Photo: Pekka Tuuri

More information:

Miina Mäki

Head of Programme

miina.maki@jnfoundation.fi +358 50 576 3298

What is common eelgrass?

• Common eelgrass is a key species in the Baltic Sea. It forms extensive and dense seabed meadows that teem with life, just like coral reefs. Common eelgrass meadows provide food and shelter for dozens of species in the Baltic Sea. The roots of these dense meadows bind bottom sediment, which reduces erosion and turbidity. Water quality improves too, as the meadows bind nutrients contained in the water.
• Common eelgrass thrives on sandy bottoms and uses its roots to spread over large areas. A variety of gastropods and crustaceans graze in these meadows – which also provide food and shelter to many fish in the Baltic Sea.
• Common eelgrass meadows are effective carbon sinks. However, in the northern Baltic Sea, these meadows sequester less carbon than in the southern Baltic Sea, where natural conditions for the growth of this plant are more favourable.

Common eelgrass is in danger of disappearing

In the Baltic Sea, common eelgrass meadows have declined as a result of coastal construction and seabed dredging, for instance. However, the meadows have suffered the worst from marine eutrophication: in turbid water, not enough light reaches plants growing on the seabed. Proliferating filamentous algae have also claimed living space from common eelgrass – these fast-growing algae can spread over perennial common eelgrass meadows and smother them. In fact, common eelgrass seabeds are currently classified as Near Threatened habitats. However, marine eutrophication has been mitigated in some parts of our coasts, giving common eelgrass meadows an opportunity to recover.

In the Baltic Seagrass project, we are working with the Parks & Wildlife Finland unit of Metsähallitus to restore common eelgrass meadows in areas where it has previously grown, but has since disappeared from. Common eelgrass does not spread by means of seeds in the northern Baltic Sea – planting is carried out by collecting a small number of seedlings from thriving lush meadows and then planting them in suitable, unoccupied sandy seabeds. The goal is that these seedlings will grow to form extensive new common eelgrass meadows.

Encouraging results from previous plantings

In recent years, Metsähallitus’s marine nature conservation team has piloted the transplanting of common eelgrass in state conservation areas in the western Gulf of Finland. Monitoring results indicate that these plantings have been successful, and common eelgrass has formed dense new vegetation at some sites. Plantings have been carried out on a larger scale in Sweden and Denmark.

In recent years, underwater nature surveys on Finland’s coast have yielded plenty of information on existing meadows and seabed areas suitable for the common eelgrass, some of which are known to have once been home to eelgrass. The Baltic Seagrass project selects planting areas in cooperation with Metsähallitus’s Parks & Wildlife Finland unit on the basis of existing survey data.

Restoring biodiversity outside protected areas

The new plantings made in the Baltic Seagrass project will mainly be located outside state conservation areas. This will help to expand the seabed habitat network and restore marine biodiversity in new areas. The John Nurminen Foundation will be responsible for carrying out the plantings with the support of Metsähallitus’s Parks & Wildlife Finland unit. Metsähallitus will also monitor the newly planted meadows.

Marine nature restoration supports the objectives of the EU’s biodiversity strategy, the EU Nature Restoration Law and the 2022 United Nations Biodiversity Conference (COP 15), which seek to conserve and restore 30 per cent of marine nature by 2030.

Promoting marine nature through international cooperation

Meadows formed by common eelgrass and other seagrasses are important habitats not only in the Baltic Sea, but also the other seas of the world. Seagrass meadows are some of the most diverse habitats in the sea and also serve as significant carbon sinks, helping to combat climate change. Over the past 40 years, as many as a third of the world’s seagrass meadows have disappeared.

In the Baltic Seagrass project, our Foundation will start international cooperation with two continental European marine protection foundations. This cooperation seeks to implement concrete marine nature projects and promote marine nature protection by increasing people’s awareness of marine nature’s current state and the importance of its biodiversity to us human beings, too.

What is seagrass?

Seagrasses are the only flowering plants that live in salty seawater. They adapted to marine life back in the era of the dinosaurs, 100 million years ago. About 60 different species of seagrass live in the world’s seas. Only one of them thrives in the northern, low-salinity Baltic Sea – the common eelgrass (Zostera marina). Seagrass meadows only cover 0.1 per cent of the bottoms of the oceans, but nevertheless account for as much as 11 per cent of marine carbon sequestration. These meadows are unbeatable carbon sinks – in terms of carbon stored per area, even more effective than tropical rainforests! Seagrass meadow habitats sustain diverse life around them, including numerous fish stocks on ocean coasts. This also makes them vital for people living by the sea.

Related News

Press release

The John Nurminen Foundation is working with Metsähallitus to restore seagrass meadows to new areas

9.2.2023

All Finnish tall oil operators commit to completely preventing tall oil discharges into the Baltic Sea

More information

Eeva Tähtikarhu Project Manager, marine traffic

eeva.tahtikarhu@jnfoundation.fi +358 50 314 2102

Jyrki Vähätalo
Special adviser
Traficom
jyrki.vahatalo@traficom.fi
+358 29 534 6470

As a result of cooperation between the John Nurminen Foundation, the Finnish Transport and Communications Agency Traficom and chemical industry companies, all tall oil operators in Finland have committed to preventing tall oil from ending up in the Baltic Sea with tank washing water.

The transport of tall oil in the Baltic Sea has increased dramatically due to growth in the bioproduct industry. Tall oil has been identified as a chemical that may potentially pose a risk to marine environment.

International legislation permits tall oil tankers to discharge their tank washing water at sea, which means that hundreds of litres of tall oil can end up in the marine ecosystem along with the washing water. Tall oil and the harmful substances it contains pose a threat to marine organisms. When a ship discharges washing water, it must be sailing at least 12 nautical miles (about 22 kilometres) from the nearest coastline in waters of at least 25 metres in depth.

“In practice, this means that in the heavily trafficked yet shallow Gulf of Finland, tank washing has to be carried out in a relatively small area of the sea. If tanks cannot be emptied properly at port, or if the process is not supervised, relatively large amounts of tall oil may end up in the sea during tank washing,” says special advisor Jyrki Vähätalo from Traficom.

All Finnish tall oil operators are committed to reducing washing water discharges

The Chemical Tanker Project is being jointly carried out by the John Nurminen Foundation and Traficom. The project has identified which of the harmful chemicals that are imported into Finland by tanker pose the greatest risk to the marine environment via tank washing water, and has also sought ways of reducing these dishcarges.

“We took a concrete step towards a cleaner Baltic Sea when all tall oil operators in Finland came together to seek the best solutions for the onshore treatment of washwater containing tall oil. Some companies already had functional solutions in place,” says Eeva Tähtikarhu, the John Nurminen Foundation’s project manager.

Tall oil is used as a raw material in various chemical industry products, such as detergents, adhesives, paints and biofuels. As Finland does not produce enough tall oil to meet the needs of its refineries, crude tall oil is shipped to Finland from several other countries. Imports of tall oil have been increasing, and the industry has identified a need for cooperation in order to prevent cargo residues from ending up in the sea.

All major tall oil operators in Finland have been involved: Fintoil from Hamina, Kraton Chemicals from Oulu, Forchem from Rauma, and UPM, which operates out of Lappeenranta and imports tall oil via the port of Kotka.

“We’re delighted that all tall oil refining companies have committed to responsibly treating washing water ashore, so that tankers unloading their cargo at Finnish ports will no longer discharge tall oil into the Baltic Sea,” says Tähtikarhu.

“For us at UPM, it’s especially important to ensure that our entire value chain is as environmentally friendly as possible. This project takes our environmental action one step further, as all tall oil ships chartered by UPM are pre-washed at port and the washing water is treated responsibly,” says Maarit Mäkinen, who is in charge of UPM’s biofuel supply chains.

The next goal is to end all tall oil discharges throughout the Baltic Sea region

Now that Finland has solved its tall oil problem, the John Nurminen Foundation aims to end the discharge of tall oil washing water into the sea throughout the Baltic Sea region.

Sweden also imports a lot of tall oil. Last year, a Swedish tanker released tall oil into the Bothnian Sea along with its washing water, creating a tall oil slick almost 200 kilometres long and 500 metres wide.

The Foundation has launched cooperation with the Swedish Transport Agency and the Swedish association Coalition Clean Baltic, so that Swedish tall oil refineries will also treat their washing water ashore in the future.

“We’re cooperating with the authorities and our international partners to ensure that the discharge of tall oil into the Baltic Sea during tank washing will be more strictly limited in the future, but changing international regulations is a slow process. It’s therefore vital for responsible companies to already commit at this stage to discharges reductions measures that go beyond the minimum limits set in legislation,” says Ulla Rosenström, director of marine environment at the John Nurminen Foundation.

Read more about the Chemical Tanker Project:

Projects

The Chemical Tanker Project

Project reduces discharges of harmful substances into the Baltic Sea from tank washing on chemical tankers.

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Goal

To reduce discharges of harmful substances into the Baltic Sea from tank washing on chemical tankers

Schedule

2022-2024

Status

The project, which concluded in 2024, identified the most harmful tank washing discharges affecting the marine environment and successfully eliminated crude tall oil, benzene and half of styrene discharges from Finland into the Baltic Sea. International cooperation was initiated to reduce chemical emissions across the entire Baltic Sea region.

Project partners

the Finnish Transport and Communications Agency Traficom, the Swedish Transport Agency, Coalition Clean Baltic

Location

Finland and Sweden

Chemical tanker in a port. Photo: Traficom

More information

Juulia Suikula

Project Manager, marine traffic

juulia.suikula@jnfoundation.fi +358 50 360 4858

The objective is to reduce discharges of hazardous chemicals into the Baltic Sea

When a tanker carrying liquid bulk cargoes – that is, chemicals – washes its tanks, this can result in the discharge of hundreds of litres of harmful and hazardous chemicals into the sea in one go. After unloading their cargo, chemical tankers often wash their tanks with seawater en route to the next port of loading. According to international legislation, washing water containing chemicals can be discharged into the sea within certain limitations. The ship must be travelling at least 12 nautical miles (approx. 22 km) from the nearest land and the depth of the sea must be at least 25 m. In practice, this means that in the shallow Gulf of Finland, for instance, tank washing has to be carried out in a relatively small area of the sea.

Even though the washing water is diluted when it mixes with the Baltic Sea, it is advisable to avoid discharges of harmful substances. Our foundation wants to ensure that avoidable chemical flows do not burden the Baltic Sea.

The Chemical Tanker Project aimed to identify the most hazardous and harmful chemical discharges associated with tank washing in chemical tankers operating in Finnish and Swedish ports. At the same time, the project sought solutions to reduce even permitted emissions. The project was carried out by the John Nurminen Foundation in cooperation with Traficom (the Finnish Transport and Communications Agency), the Swedish Transport Agency, and the Coalition Clean Baltic (CCB).

Identifying the most harmful chemicals and their quantities

At the start of the project, a risk assessment was conducted to identify chemicals posing the greatest potential risk to the marine environment and human health. The assessment considered the environmental toxicity of chemicals, their hazards to human health, and their discharge volumes in Finland. Based on the findings, the project focused on finding solutions to reduce cargo residue discharges of styrene, crude tall oil, and benzene. These substances are used in the chemical industry for producing plastics, paints, adhesives, and biofuels. Additionally, a similar risk assessment was initiated in Sweden.

Seeking solutions to reduce emissions in cooperation with various actors

Collaboration with ports, chemical industry companies, and other stakeholders played a key role in identifying the best methods for reducing chemical emissions. Together with the chemical industry, the project gathered information on various tank cleaning methods and explored opportunities for wastewater treatment and reuse. Once the best practices were identified, they were introduced to companies through workshops specifically tailored for companies handling the same chemicals.

Chemical discharges from tank washing can be reduced by improving tank emptying and washing methods as well as by treating tank washing waters more effectively. For instance, cost-effective onshore treatment solutions already exist for crude tall oil and styrene, allowing cargo residues to be reused instead of being discharged into the sea.

As a significant result of the project all Finnish crude tall oil company, the only benzene using company and ½ styrene using companies committed to responsibly managing their tank washing waters onshore. As a result, these tankers in Finnish ports no longer discharge chemical residues into the Baltic Sea. Given the increasing import volumes of crude tall oil to Finland, the industry recognized the need for cooperation to prevent cargo residues from entering the marine environment.

The project also promoted the reduction of tank washing discharges on an international scale. Together with Traficom, CCB, and the Swedish Transport Agency, efforts were made to advance measure S16 under the Baltic Sea Action Plan (BSAP) of the Helsinki Commission (HELCOM), which focuses on reducing chemical emissions into the Baltic Sea. Through international cooperation, progress was made in conducting risk assessments in other HELCOM countries, as well as exploring further measures to reduce chemical discharges across the Baltic Sea region through EU and IMO measures.

Materials related to the project

Finnish Risk AssessmentLataa

In cooperation with

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Art brings light to beautiful and vivid habitats at Helsinki Biennial 2025

Text

Helmi Pörhölä Communications Specialist

helmi.porhola@jnfoundation.fi +358 50 471 1078

Common eelgrass, Zostera marina, is a seagrass species that can be found in the Baltic Sea. Artists of LOCUS, Thale Blix Fastvold and Tanja Thorjussen, created an artwork for Helsinki Biennial 2025, exploring and celebrating the species. During their visit to Tvärminne Zoological Station, the artists met with Camilla Gustafsson, a long-time researcher of common eelgrass.

The Oslo-based artists Thale Blix Fastvold and Tanja Thorjussen are one of the artists of Helsinki Biennial 2025. As a partner of the event, John Nurminen Foundation has supported and engaged in the work progress of LOCUS – for instance, by facilitating travel to Tvärminne to explore common eelgrass.

Fastvold and Thorjussen have long engaged with non-human creatures – such as pollinators and plants – in both river and marine environments. Their deep interest in common eelgrass, however, began during a visit to Tvärminne Zoological Station, where they encountered the plant firsthand.

“It was not so much that we reached out to eelgrass, it was more like eelgrass reached out to us”, Thorjussen says.

Common eelgrass – a key species of the Baltic Sea

Tvärminne Zoological Station is a marine research station of the University of Helsinki, located in the central/northern Baltic Sea, near the city of Hanko. The research at the station dates to 1902 when it was established.

Camilla Gustafsson, an academy research fellow at the station, studies marine ecosystem functioning, with a focus on seagrasses and other aquatic plants.

“Common eelgrass is a key species in the Baltic Sea and plays an important role in the shallow coastal ecosystems. The common eelgrass is a seagrass, an aquatic plant that forms underwater meadows. These meadows provide habitat and shelter for many species, produce oxygen, bind nutrients, and stabilize bottom sediments. Common eelgrass also sequester carbon, although the extent varies depending on location and growing conditions”, Gustafsson explains.

Variety of segrass species

Gustafsson explains that there are different kinds of seagrass species around the world. Some species are large and slow-growing, while others are smaller and faster-growing. For example, the Mediterranean seagrass species, Posidonia oceanica, is a kind of climax species: it is large, grows slowly and is long-lived.

The Baltic Zostera marina is somewhere between the two extremes: not the smallest and fastest-growing, but it is not quite as large and slow-growing as the Mediterranean grass either.

What all seagrasses have in common is that they are adapted to salty waters and have underground stems (rhizomes) and roots that help them anchor to the seafloor and provide them with nutrients for growth. Like many plants on land, seagrasses reproduce by flowers and seeds, but also asexually (clonally) by growing runners along the seafloor similarly to, for example, strawberry plants.

Imagining a bright future for common eelgrass

Common eelgrass is threatened by a cocktail of anthropogenic stressors: from the constant pressure of eutrophication to marine heatwaves intensified by climate change.

However, in their Biennial artwork, Fastvold and Thorjussen have chosen to create positive imaginations and visualizations for common eelgrass.

“When you love something, you want to take care of it. The stories that humans tell and hear shape our understanding of both the past and the future. We need to be able to envision a future to work towards”, Thorjussen says.

When visiting Tvärminne in 2024, the artists learned about eelgrass through the scientists and their research.

“We felt that, in a way, they are looking at dystopian future scenarios: what will happen if the water gets warmer or fresher. For us it was a good starting point to approach the future from a positive perspective. As artists, we can and like to ask questions that are a bit different and creative”, Fastvold explains.

The flowering of Zostera marina

The focus on positive scenarios led the artists to explore how common eelgrass reproduces. In the Baltic Sea, common eelgrass spreads by runners along the seafloor, by cloning itself.

“We started asking questions like, ‘Why?’ and ‘Would it be better for common eelgrass to reproduce sexually as well?’ Through some research papers we discovered that reproducing sexually would increase the genetic diversity of eelgrass, which could help it be more resilient and better able to survive different climate change scenarios” Fastvold explains.

While not based on scientific eelgrass flowers, the artists wanted to imagine the flowers of common eelgrass, inspired by their reproduction. This kind of speculation is at the very heart of their artwork.

The seagrasses often react to heat by flowering, yet in the central and northern Baltic Sea the seeds never develop into viable plants.

Myths meet scientific information

The artwork of LOCUS includes a sound work – a spell to honor Zostera Marina. It takes inspiration from a 4400-year-old poem written by Enheduanna to Sumerian goddess Inanna.

“We were inspired by this ancient text that was created thousands of years ago and wanted to bring Zostera Marina (the goddess) to light in a mythological way. So, we used the rhythm and structure of the hymn as a base and incorporated phrases and words from scientific papers that Camilla provided us to create the sound work. Then we of course added some magic of our own”, Thorjussen says.

The poem is read by the artists in unison with a hauntingly beautiful sound. In the background you hear underwater sounds the artists recorded in areas where eelgrass grows: in Tvärminne and in the port of Helsinki, where some industrial sounds can also be heard.

The Zostera Marina’s Song of Increase concludes with words that offer a sense of calmness:

We see futures of eelgrass meadows already thriving!
We see futures of healthy waters and rivers
We see a Baltic Sea flourishing and flowering in peaceful abundance
We see you Zostera

This Song of increase is yours Zostera

Hope and emotion can keep us moving

Fastvold and Thorjussen wish to give people hope – and even deeper, love – towards the underwater life and Zostera marina.

“We want people to feel that, despite the worrying scenarios and challenges, decision-makers, individuals and society at large can take meaningful action”, Fastvold says.

But does Camilla, whose research largely centers on environmental change, still have hope?

“I cannot just give up on hope – I want to believe that things will take a turn for the better. It would also be beneficial for people to hear and see that the Baltic Sea also has beautiful and vivid habitats. The Baltic Sea holds so much worth protecting, and its wellbeing should be a concern”, Gustafsson says. 

When data and facts no longer spark sufficient action, storytelling and evocative expression can help us move forward.

---

Helsinki Biennial 2025 takes place from 8 June to 21 September across three venues: Vallisaari island, HAM Helsinki Art Museum, and, for the first time, Esplanade Park in central Helsinki.

The work of LOCUS can be experienced at Helsinki Biennial in Vallisaari and HAM Helsinki Art Museum.

Read more about the Biennial

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Hundreds or even housands of litres of hazardous chemicals may be discharged into the Baltic Sea

More information

Eeva Tähtikarhu Project Manager, marine traffic

eeva.tahtikarhu@jnfoundation.fi +358 50 314 2102

Within the framework of international legislation, carcinogens and other chemicals that have been proven to be harmful to aquatic organisms can be discharged into the Baltic Sea along with tank washwater. Companies that use chemicals should be required to take responsibility for the emissions of their entire transport chain.  

Carcinogens and other chemicals are likely to end up in the sea at least on a weekly basis. 

According to international maritime regulations, tankers are allowed to discharge chemicals into the sea with tank washwater under certain conditions: the ship must be at least 12 nautical miles (about 22 km) from the nearest shore and the sea must be at least 25 metres deep. 

“In the shallow Gulf of Finland, this means that tank washing is in practice carried out in a relatively small area. Large volumes of many different chemicals end up in this area, and their combined effects on marine organisms are not properly understood,” says Eeva Tähtikarhu, Project Manager for the John Nurminen Foundation’s maritime traffic projects.  

There are several major chemical ports in the Gulf of Finland, and the most important ones on the Finnish side are Kilpilahti in Porvoo and HaminaKotka. 

Chemical emissions always pose a risk to marine environments

In the Chemical Tanker Project, the John Nurminen Foundation and Traficom have analysed both the harmful chemicals that tankers are discharging into the Baltic Sea and their effects on the marine environment. They have also reduced chemical emissions in collaboration with chemical industry companies.  

The project has identified the three most significant high-risk chemicals that may be discharged into the sea at Finnish ports: tall oil, styrene and benzene. Tall oil emissions have now been completely prevented, but styrene and benzene are still being discharged into the sea.  

Styrene and benzene are carcinogenic and mutagenic substances that have been proven to be harmful to aquatic organisms.  

“The project has calculated that a single ship can discharge hundreds or even thousands of litres of chemicals into the sea at a time along with its tank washwater. Styrene is still being discharged into the sea every few weeks from ships unloading at Finnish ports,” says Tähtikarhu.  

The solid vegetable oil that ended up on Hanko’s beaches made these chemical discharges visible, but most emissions are difficult to detect, as many chemicals are invisible in seawater.  

“Although chemical emissions get diluted by seawater, scientific models have shown that even legal discharges of the most harmful chemicals will always pose a risk to marine environments.” 

Some discharges are also illegal. Monitoring in Sweden detected discharges of tanker washwater in nature conservation areas. Tankers have also been observed discharging excessive amounts of chemicals into the sea in contravention of international regulations, and tank washing has been carried out too close to the shore.  

Tall oil operators set an example for the entire sector

Companies that use chemicals should be required to take responsibility for the emissions of their entire transport chain. Companies that use hazardous chemicals should ensure that the ships they use do not discharge any cargo residues into the sea. In the best case scenario, if tanks are washed at the port where the cargo is unloaded, any residues will be collected for reuse. 

“The tall oil industry is an example of how an entire sector has taken joint responsibility for its emissions throughout the transport chain. All companies transporting tall oil in Finland are committed to ensuring that the ships transporting their cargos wash their tanks ashore. This guarantees that no tall oil residues end up in the sea,” says Tähtikarhu.  

Tank washing at port would also be technically feasible for styrene and benzene, but would entail additional costs for the companies using the chemicals, and may also require ships to spend longer in port.  

“We’ve been advocating for stricter international regulations on tank washwater. However, international regulations are slow to change and enforcing them at sea is extremely challenging. Which is why the most effective way to reduce chemical emissions is for companies to commit to recovering their tank washwater,” says Annamari Arrakoski-Engardt, CEO of the John Nurminen Foundation. 

Projects

The Chemical Tanker Project

Project reduces discharges of harmful substances into the Baltic Sea from tank washing on chemical tankers.

Read more

Blog Post

Tackling chemical tanker pollution: time for companies to take responsibility

4.3.2025

Press release

Finnish tall oil operators commit to completely preventing tall oil discharges into the Baltic Sea

7.9.2023

Press release

Cooperation between the John Nurminen Foundation and Traficom reduces chemical emissions into the Baltic Sea

23.11.2022

HELCOM: The state of the Baltic Sea remains Worrying – the sea needs our help

How is the Baltic Sea doing, and what is to be expected in the future? HELCOM (the Baltic Marine Environment Protection Commission) published its third holistic assessment of the Baltic Sea, called HOLAS, in October 2023. The assessment examines the state of the ecosystem health of the Baltic Sea between 2016-2021.  

As the name suggests, HOLAS is a comprehensive, holistic assessment of the state of the Baltic Sea. It assesses the total impacts on the sea focusing on five thematic areas: biodiversity, eutrophication, hazardous substances, economic and social analyses, as well as spatial analyses of pressures and impacts.    

The message of the assessment does not give us much to celebrate: the assessment shows only little or no improvement in the state of the sea. The assessment is done using almost 60 different indicators that show the pressures on the sea and the state of its biodiversity. All three assessed categories of pressures on the sea – eutrophication, hazardous substances, and commercial fishing – are on an unsustainable level or have not decreased enough. 

The major challenge of eutrophication

Eutrophication remains a major problem for the ecosystems and the services they provide in the Baltic Sea region.  

Lotta Ruokanen, Professional Secretary at HELCOM, notes that although the nutrient inputs have decreased significantly, the status of the sea is mostly below the good environmental status threshold. However, noteworthy and somewhat positive is that only 1,3 percent of the sea area is in the worst category, bad status. 

Ruokanen also points out that in terms of water transparency, oxygen debt, shallow water oxygen, and state of the soft-bottom macrofauna community, the status is good in the Bothnian Sea, Bothnian Bay and Kattegat.  

There are multiple reasons why good status in different categories has not been achieved: i.e. changes in ecosystems may happen with a time lag, “new” challenges such as climate change arise, and some measures have yet to be implemented while some might be insufficient. 

The importance of assessing the state of the Baltic Sea

HOLAS provides necessary information for those protecting the sea. For example, John Nurminen Foundation bases its work on the best available scientific information to save the Baltic Sea most effectively. Thus, information on how different measures and actions are working is critical. 

Ulla Rosenström, the Director of Marine Environment at John Nurminen Foundation, says that HOLAS3 shows both that where agreed protection measures were implemented they have in fact been effective and that the work needs to be continued. We can also identify the areas that need special attention. 

Rosenström notes that along with assessing the state of the environment, following the past and future trends is important. Solely knowing the present state does not tell us whether protection measures are optimal.  

The high cost of inaction

The sea knows no boundaries, so concerted action is needed between Baltic Sea states as well as the European Union. It is key to consider societal, economic, and ecological connections as the three are in fact interconnected.  

Rüdiger Strempel, the Executive Secretary of HELCOM, points out a striking figure in the assessment: “The poor environmental status of the Baltic Sea has been shown to impact a wide range of ecosystem services on which we depend. The cost of inaction is therefore high.” 

The estimated yearly worth of achieving good environmental status (GES) in national marine waters by 2040 is 5.6 billion euros for the people around the Baltic Sea. 

To reach a good environmental status, transformative change is needed in all marine-related societal and economic sectors. Well-informed public decision making is crucial en route to change.  

The change requires a shared knowledge and understanding of the status of the sea and the objectives of actions to improve the status. According to Strempel, only a shared understanding can lead to targeted and effective measures as duplication of efforts can be avoided and efficiency maximized. 

The necessary but challenging indicators 

According to Rosenström, it is vital to look at the multiple pressures that can affect the same ecosystem. If they are viewed separately, the combined effects might go unnoticed.  

While using different indicators of the effects is important in assessing the environmental status, combining them into an index can be challenging, as the combined indicators might change in opposite directions. When publishing results, it is crucial to explain how the different indicators work – particularly to support well-informed decision making. 

“For example, the heaviness of nutrient load might not go hand in hand with the state of some species”, Rosenström specifies. 

Ruokanen likewise explains that the HOLAS assessment is done on the most integrated level: e.g. it combines all eutrophication indicators. Considered separately, the indicators of nutrient levels, direct effects and indirect effects show more variety in their results.  

Climate change requires attention

According to Ruokanen, climate change is something that needs a lot of attention. What’s notable is that climate change mitigation and marine protection often support each other. 

“There are signs of combined efforts and synergies in policies on e.g. simultaneous climate change mitigation, adaptation and improving the biodiversity status”, says Ruokanen. 

So, as the new year progresses, further work on saving the Baltic Sea is needed. While “new” pressures, such as climate change, make the protection work as pressing as always, it is not too late to save the sea.  

What is HOLAS?

The Baltic Sea countries have agreed on a strategic programme called Baltic Sea Action Plan (BSAP) – adopted first in 2007 and updated in 2021. Aligned with the UN Sustainable Development Goals, and the EU Marine Strategy Framework Directive, the aim of the BSAP is to achieve a good environmental status of the Baltic Sea. The progress is followed up with HOLAS to review how the taken measures and actions are working.  

Hundreds of experts from various fields contribute to the assessments done roughly every six years. The HOLAS 3 report was published in its totality in October 2023.

Go to HOLAS 3 website

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Annual report 2024 has been published

7.5.2025

New guidelines for reducing nutrient emissions in ports in the Baltic Sea are completed – implementation would almost entirely eliminate nutrient emissions from ports

More Information

Juulia Suikula

Project Manager, marine traffic

juulia.suikula@jnfoundation.fi +358 50 360 4858

Guidelines on the best techniques and working practices that can be used in ports to minimize nutrient discharges into the Baltic Sea are on their way to becoming an international recommendation by the Baltic Marine Environment Protection Commission HELCOM. The guidelines prepared under the leadership of the John Nurminen Foundation contain dozens of recommendations for, among other things, the loading of fertilizers and personnel training.

In the Baltic Sea fertilizer ports, a significant amount of fertilizer loss is generated each year, contributing to the eutrophication of the sea. Research results collected in the Fertilizer Shipping Project of the John Nurminen Foundation show that hundreds of kilograms of phosphorus and hundreds of tons of nitrogen can enter the sea from busy fertilizer ports every year through stormwater alone. This load corresponds to a nutrient load from wastewater treatment plants of a medium-sized city.

To reduce nutrient emissions from ports, experts from the John Nurminen Foundation, Race for the Baltic, and Coalition Clean Baltic have developed new guidelines. These BET/BEP guidelines encompass 67 measures that implement best available technology (BAT) and best environmental practices (BEP) aimed at minimizing fertilizer loss during storage, handling, and transportation.

“The guidelines offer ports, operators, shipping companies and other operators involved in fertilizer shipping, as well as authorities and politicians, concrete tools to prevent fertilizer emissions. The goal is to improve the control of emissions and to instill sustainable operating methods in the daily practices of operators,” says Juulia Suikula, project manager of maritime transport projects at the John Nurminen Foundation.

The guidelines are based on a combination of information, literature, and interviews with international maritime transport operators in the Baltic Sea, collected through the foundation’s own project and sourced from partners. For the document, comments were collected from Sweden, Denmark, Finland, Poland and Lithuania. The John Nurminen Foundation has been responsible for the preparation of the guidelines with the help of the consulting firm CE Delft.

A possibility to reduce emissions to nearly zero

As a result of the work that began in 2019, many solutions to reduce fertilizer loss and nutrient load have been found. The solutions are concrete, starting with loading practices and cleaning the loading area. Developing the skills of port operators and the efficiency of public authorities were also found effective.

The solutions presented in the guidelines include, e.g., regular maintenance of loading buckets, a closed loading system, covering of stormwater wells, use of protection between the ship and the berth, regular and efficient cleaning of berth and storage areas, training of personnel, monitoring of stormwater nutrient concentrations, and investments in stormwater collection and cleaning systems.

The guideline is on its way to become an official recommendation of HELCOM during the next year, and it will also be used to implement the Commission’s Baltic Sea Action Plan (Baltic Sea Action Plan).

“According to preliminary estimates, ports can reduce their nutrient emissions by up to half by implementing a few guidelines. Even with small investments, significant emission reductions can be achieved inexpensively, and the guidelines detail the cost-effectiveness of different measures. By implementing all the recommendations, it is possible to eliminate fertilizer emissions almost completely,” Suikula sums up.

With the adoption of the recommendation, HELCOM member states should report to the Commission on the national implementation of the guidelines every four years, starting in 2027.

See the Guidelines

Read more

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Thousands of litres of hazardous chemicals may be discharged into the Baltic Sea

11.3.2025

Blog Post

Tackling chemical tanker pollution: time for companies to take responsibility

4.3.2025

News

Fertiliser ports have the potential to make major emission reductions

2.2.2024