Is it legal to record a meeting in Finland?

Rikoslaki ch. 24 § 5, salakuuntelu, eavesdropping. Finland publishes an official English translation, so the wording is quotable directly: "A person who unlawfully listens to or records with a technical device 1) a discussion, talk or other sounds of private life, where these are not intended for his or her knowledge and which occur or arise in a place covered by the right to domestic privacy, or 2) secretly, elsewhere than in a place covered by the right to domestic privacy, talk that is not intended for his or her knowledge or for the knowledge of any other third parties, where the circumstances are such that the speaker has no reason to believe that a third party is listening, shall be sentenced for eavesdropping to a fine or to imprisonment for at most one year."

An attempt is punishable. 24:7 criminalises preparation, and 24:8 is the separate offence of dissemination of information violating personal privacy.

The framing is speech not intended for the recorder's knowledge. That is not non-participation as such, but functionally the same test, because speech addressed to you in a meeting is by definition intended for your knowledge.

Yes, and the Data Protection Ombudsman said so on exactly this question. In an opinion of 30 August 2007, asked by an occupational safety representative about recording conversations with a supervisor in a workplace bullying situation: "Yleisenä ohjauksena tietosuojavaltuutettu totesi, että työntekijä saa nauhoittaa puhelut ja keskustelut, joihin itse osallistuu. Tällöin ei voine syyllistyä rikoslaissa tarkoitettuun salakuunteluun."

As general guidance, an employee may record calls and conversations in which they themselves take part, and in doing so could not commit the eavesdropping offence.

Two caveats the opinion carries with it. First, it is from 2007 and its data protection reasoning is pre-GDPR: it says an employee's own recording would generally fall outside the scope of the then Personal Data Act as processing for ordinary private purposes. That Act was repealed and the household exemption under Art. 2(2)(c) GDPR is read narrowly, so that sentence should not be recycled as current authority for a professional running an always-on transcriber.

Second, the same opinion is clear that use is the exposed step, not recording: "Eri asia on, miten aikoo nauhoitteitaan jatkossa käyttää", it is a different matter how you intend to use the recordings, and playing them to others can amount to defamation, dissemination of information violating private life, or disclosure of statutorily protected information such as a trade secret or health data.

Nothing is legally required of a participant, but the Ombudsman recommends telling the other party and says so in the same opinion: good and proper practice at the workplace would nevertheless include informing the other party of the recording, "varsinkin jos keskustelu on tarkoitus käydä luottamuksellisesti kahden osapuolen, esimerkiksi työntekijän ja esimiehen välillä", especially where the conversation is intended to be confidential between two parties, for example an employee and a supervisor.

Quick note before we start: I'm recording this so I can write my notes up afterwards. It transcribes on my laptop, nothing goes to the cloud, and I only keep the text. Say so now if you'd rather I didn't.

So Finland's answer is: legally permitted, notice recommended rather than required. Longer versions are on telling people you're recording.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

Employee processing is governed by the working-life privacy act, laki yksityisyyden suojasta työelämässä (759/2004, as amended), which imposes a necessity requirement on all employee data and regulates when an employer may collect data without consent. We did not open the section text.

The employee-representation trigger in Finland is the co-operation procedure, and the Ombudsman states the principle directly: "Työntekijöiden paikantaminen on teknistä valvontaa, joka tulee käydä läpi työpaikan yhteistoimintamenettelyissä." Locating employees is technical monitoring, which must be gone through in the workplace co-operation procedures.

That quote is about location tracking. An always-on transcriber is technical monitoring on the same reasoning, but the extension is ours rather than the Ombudsman's, and we did not open the co-operation act itself.

The Office of the Data Protection Ombudsman, and Finland is the best-sourced country in this survey alongside Norway: an official English translation of the statute plus an on-point opinion, both read in the original.

Its position in one line: an employee may record conversations they take part in without committing eavesdropping, telling the other party is good practice rather than a requirement, and the exposure is in how the recording is later used and shared.

Because the binding layer in Finland is data protection rather than criminal law, this is where the product's architecture does real work. Transcription runs on your own device, the audio is never written to disk, and nothing is sent anywhere. There is no cloud component, so on our reading we are not a processor under Art. 4(8), which processes personal data on behalf of a controller and presupposes receiving it. That means no Art. 28 data processing agreement to sign with us, no sub-processor list, no international transfer and no transfer impact assessment, because there is no transfer. We found no decision squarely holding that an on-device-only vendor is not a processor, so that is reasoning you can check rather than a settled point.

What it does not do is disclose anything. There is no bot in the participant list and no banner on anyone else's screen, so the transparency obligation rests entirely on you saying something. Earkeep does not make anyone compliant and could not: a tool cannot be compliant, only a processing operation can be lawful.

Where it helps in the room is that stopping is real and checkable. A pause from the live edge releases the microphone and the system audio stream, so your operating system's own recording indicator goes dark in front of the person who asked. A meeting on a connected calendar can be marked never-record. And a stretch of the day, or a saved meeting with its transcript, can be purged from the file on your own disk, with no server copy anywhere to reconcile against.

• Criminal Code, official English translation (ch. 24 § 5)
• Rikoslaki 24 luku (Finnish original)
• Data Protection Ombudsman, opinion 2007/223
• Tietosuoja.fi, the working-life privacy act
• Tietosuoja.fi, FAQ on working life
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.