This chapter focuses on the right to participation in Finland and its evolution throughout recent history. First, it reviews the key legal frameworks governing the right to participation before elaborating on the myriad opportunities available to Finns to participate in policy making in practice, both at the national and local levels. It also emphasises a number of innovations and digital tools being explored in Finland to promote and strengthen civic participation while discussing related challenges. Finally, the chapter provides recommendations under each sub-heading.
Civic Space Scan of Finland
OECD Public Governance Reviews
6. Civic participation in Finland
Abstract
Introduction
The legally mandated right of participation has developed and evolved rapidly since the 1970s in Finland. Since the 1990s, these changes have picked up pace and opportunities for direct participation have been added to the traditional focus on representative democracy. Finland’s commitment to civic participation, as part of its commitment to democracy more generally, extends from its Constitution to legislation, policy and practice, from the central government across the ministries and right down to the municipal level. It is underpinned by a strong commitment to transparency and openness and facilitated by high levels of trust in governance institutions (such as the President, authorities, Prime Minister, the government), and a tradition of consultation and consensus democracy, based on shared power (Pehkonen and Hyry, 2020[1]). Nevertheless, people’s socio-economic status matters. In this respect, the CONTRE Consortium of Trust Research project (2015-19) found, for example, that people with lower levels of education were less trustful of politicians and political institutions and perceived that they could not influence decision making, whereas highly educated and more affluent people trust the political system more (Bäck and Kestilä-Kekkonen, 2019[2]).
Among the public, there is a relatively high level of support for involving citizens further in decision making and in political processes. Survey data from Sitra show that 62% “fully agree” or “agree to some extent” that decision makers should take account of the views of citizens by means of online voting or surveys (Pehkonen and Hyry, 2020[1]). There is mixed support for the use of referenda, which in any case are rare: 49% “fully agree” or “agree to some extent” that the more frequent use of referenda would lead to “bad and short-sighted decisions”, whereas 45% feel that important issues should increasingly be decided by referenda (Pehkonen and Hyry, 2020[1]). Different demographic groups favour different models. Participatory democracy is favoured by younger and more educated people, whereas direct decision making (i.e., referenda) is more strongly supported by those with less education and poor knowledge of politics, who favour more radical shifts (Bäck and Kestilä-Kekkonen, 2019[2]). A recent study for the Ministry of Finance cautions against involving citizens more in political processes to generate support from one group in society, while possibly alienating others (Bäck and Kestilä-Kekkonen, 2019[2]).
A related point is that a significant number of Finns are reluctant to share their views on societal issues due to fear. A nationally representative survey conducted by Yle in 2020 with a sample of 2 440 respondents asked citizens whether they agreed or disagreed with the following statement: “I can share my thoughts about societal issues without being afraid of other people’s reactions.” Five per cent of the respondents “disagreed completely” and 19% “disagreed”, which indicates that almost one-quarter of Finns feel they cannot share their thoughts because they are afraid of others’ reactions.1 This phenomenon holds true among different groups of respondents: among highly educated people who find the discussion culture in Finland too aggressive, 35% are too afraid of others’ reactions. On the other hand, among mainly women and young people who are less educated or think they do not have much to say, they survey concludes that 30% of them feel too scared to share their views.2
Review of key legal frameworks
The right to participation in public life is firmly grounded in Finland’s Constitution and safeguarded in legislation. Chapter 2, Section 14 of the Constitution guarantees the right of every Finnish citizen and every foreigner permanently residing in Finland, and over 18 years of age, to vote in municipal elections and municipal referenda. It adds that “[t]he public authorities shall promote the opportunities for the individual to participate in societal activity and to influence the decisions that concern him or her” (emphasis added) (Ministry of Justice, 1999, latest amendments in 2018[3]). This provision is given further weight in several laws and related guidelines, particularly in relation to the environment and land use (Jäske, 2018[4]). For example, Section 20 states that “public authorities shall endeavour to guarantee for everyone the right to a healthy environment and for everyone the possibility to influence the decisions that concern their own living environment.”
The Citizens’ Initiative Act, in force since 2012, governs citizen initiatives at the national level and is considered a significant democratic innovation in Finland, even though in practice, most of them are rejected in parliament. Chapter 4, Section 53 of the Constitution states that an initiative may be submitted to parliament if at least 50 000 Finnish citizens entitled to vote (about 1.2% of the total electorate) have signed it. Initiatives must take the form of a proposal for a new law, or a repeal or amendment to an existing law and must concern a subject that falls within the legislative powers of parliament. This excludes issues related to international obligations, for instance. Crucially, there is a six-month time limit for the collection of signatures and the development of the proposal. Once the signatures have been checked by the Population Register Centre, a spokesperson for the initiative can submit it to parliament, which then has an obligation to consider it (Parliament of Finland, n.d.[5]). This is followed by a preliminary debate on the matter and a referral to a committee, to which spokespersons must be given the opportunity to present their case. The relevant committee may then prepare a report supporting the initiative – with or without alterations – for another plenary session of parliament or decide not to support it at all. If the committee decides not to support it, the initiative is not necessarily rejected and can, at least in theory, be carried forward by another action, such as a government proposal (Parliament of Finland, n.d.[5]). Parliament must discuss initiatives that are carried forward and vote on them.
The very purpose of the Local Government Act, adopted in 2015, is to “establish the conditions in which, in municipal activities, the self-government of the residents in a municipality can take place and opportunities can occur for the residents to participate and exert an influence” (Ministry of Finance, 2015[6]). The act provides for the establishment of local council groups (Chapter 4, Section 19), youth councils (Section 26), older people’s councils (Section 27) and disability councils (Section 28) to engage on issues of particular importance to those groups, in addition to the right to vote in local referenda. Section 22 states that residents and service users have the right to participate and influence the activities of the municipality and that local councils must ensure that there are “diverse and effective opportunities” to do so. Each municipality is free to decide how to put this obligation into practice and which tools to use, but several examples of potential activities are suggested. These include setting up local resident panels; finding out residents’ opinions before taking decisions, electing representatives of service users to municipal decision-making bodies; arranging opportunities to participate in the planning of the municipality’s finances, planning and developing services with service users, and supporting independent planning and preparation of grass roots activities (Ministry of Finance, 2015[6]). In practice, there are large differences in the methods used in different municipalities.
The Local Government Act, also allows for citizen initiatives at the municipal level Chapter 1, Section 23 states that all residents and corporate entities and foundations operating in municipalities have “the right to submit initiatives on matters concerning the municipality’s activities” (Ministry of Finance, 2015[6]). Such initiatives must come from a group constituting at least 2% of the municipality’s residents and the matter must be considered within six months of it being initiated (Section 23). Furthermore, service users have the right to submit initiatives regarding services and the council must be informed of all such initiatives, and related actions, at least once a year. Every municipal initiative must be considered and referred to the relevant authority in the proper jurisdiction, typically the municipal government, a board or a municipal authority. Similarly, all residents over the age of 15 can submit referendum initiatives or requests to hold a municipal-level referendum (Chapter 1, Section 25). At least 4% of the municipalities’ residents must be behind such an initiative and the local council must decide “without delay” on whether to hold such a referendum. However, such referenda are advisory in nature, however (Setälä et al., 2020[7]). This implies that the decision to hold a referendum is taken by elected representatives who also take the final decision on the issue under consideration (Setälä et al., 2020[7]). Such local opportunities to influence decision making are viewed as being “soft” forms of direct democracy.
Chapter 1, Section 2(1) of the 2017 Youth Act complements the above. It states that the purpose of the law is to “promote the social inclusion of young people and provide them with opportunities for exerting an influence …” (Ministry of Education and Culture, 2017[8]). It references the Local Government Act, adding that local and central government authorities “shall offer and organise opportunities for young people to be involved and exert an influence in the processing of issues related to local, regional and nationwide youth work and policies, or otherwise ensure that they are consulted in said contexts” (Chapter 6, Section 24). Furthermore, “young people shall be consulted in matters that affect them” (Ministry of Education and Culture, 2017[8]). In various environmental laws related to mining, climate, environmental protection and nature protection there are also provisions guaranteeing participation in general, the participation of CSOs and the participation of the Sámi Parliament. However, despite the reforms described above to introduce direct citizen participation opportunities, they have not actually “introduced more authority and decision making power to citizens” (Jäske, 2018[4]). In her research on this area, Jäske notes that “a representative ethos” remains strong in Finland’s political system and that direct democracy is still “rare” in Finnish politics at both national and municipal levels (Jäske, 2018[4]). Yet, they still play an important role by informing decision makers and by providing avenues for the public to express its views.
Policy and political environment
Various governments have introduced decisions in principle to provide guidance on civic participation and consultation on the preparation of legislation. These have been bolstered with cross‑government commitments to participation in several key policy frameworks. These include: the Open and Equal Involvement Government Democracy Policy report (2014) (Ministry of Justice, 2014[9]), the National Action Plan on Democracy Policy 2017-2019, the National Action Plan on Fundamental and Human Rights (Ministry of Justice, 2017[10]), the National Democracy Programme 2025 (Ministry of Justice, 2019[11]), and the latest government programme (Government of Finland, 2019[12]). The government programme pledges to develop new ways to engage different stakeholders in reforming society by involving people more in public administration activities and by searching for and testing new ways of interacting (Government of Finland, 2019[12]). It also commits to improved consultation practices and impact assessments of these.
The cross-government National Democracy Programme 2025 was developed as a response to what is perceived as growing inequality in participation and the alienation of decision makers from people’s everyday lives presenting a growing challenge to Finnish democracy. This manifests itself in relatively low voter turnout, at least compared to the other Nordic countries,3 and relatively low trust in politicians and political parties (Pehkonen and Hyry, 2020[1]). In the 2019 parliamentary elections, 72.1% of Finnish citizens resident in Finland voted (Statistics Finland, 2019[13]).4 In municipal elections, voter turnout stood at 58.9% in the last elections in 2017 (Statistics Finland, 2017[14]).5 Turnout has fallen since the 1960s for both men and women, from a high of approximately 86% in 1962 to 70.6% for men in 2019, and from 84% in 1962 to 73.5% for women in 2019 (Figure 6.1) (Statistics Finland, 2019[15]). Socio-economic background plays a key role in voting patterns: voter turnout for the top 20% of the population is estimated at 75%; for the bottom 20% it is estimated at 62% (OECD, 2020[16]). This is in line with the OECD average gap of 13 percentage points (OECD, 2020[16]). The effect of income on voter turnout is linear: in the 2019 parliamentary elections, the percentage of voters in the bottom income decile was 57.7%, whereas it was 87.1% in the top income bracket (Mattila, 2020[17]). The effect is that more educated people – as candidates and voters – have a disproportionate impact on policy making (Grönlund and Wass, 2016[18]). A serious challenge for Finnish representative democracy is, therefore, “how to avoid concentrating political influence in the hands of the well-off and undersized elites” (Grönlund and Wass, 2016[18]).
Figure 6.1. Turnout by gender in parliamentary elections, Finnish citizens living in Finland, 1945‑2019
Source : Statistics Finland (2019[15]).
The government views what it describes as “growing inequalities in civic participation” and the decline in the voter turnout as the greatest weaknesses of the democratic system in Finland (Ministry of Justice, n.d.[19]). It observes the fact that interest in civic activities and participation only comes from some parts of society as a threat to both the democratic process and public confidence in decision making more generally. The aims of the Democracy Programme, which mirrors relevant content in the government programme, are to remedy this, including by guaranteeing equal opportunities for everyone, putting participation at the centre of the public administration’s activities, increasing trust in institutions, and improving social inclusion (Government of Finland, 2020[20]). The government programme is also very specific about engaging citizens. It pledges to enhance opportunities for direct democracy by using methods such as citizens’ juries, resident interviews, youth councils, online councils and participatory budgeting, as well as by making participation in politics and political debate “lighter and easier”, through pop‑up events (Government of Finland, 2019[12]).
Participation in policy making in practice
Legislative drafting and consultation guidance
The Ministry of Justice is responsible for promoting and monitoring the realisation of participation rights6. It has developed a seven-step Legislative Drafting Process Guide that includes a dedicated consultation phase with non-governmental actors. The seven steps are: 1) preliminary preparation; 2) regulatory drafting by a preparatory body; 3) consultation; 4) continued drafting; 5) review by the government; 6) parliamentary review; and 7) enactment. Funding for consultations is generally built into the budgets for different projects, although the requirement to do so is not legally binding. As part of the consultation phase, the ministry recommends that the relevant draft proposal, decree or regulation be sent with a memorandum and any other relevant materials to Lausuntopalvelu.fi, where public officials can publish requests for opinions and statements (see the range of digital participation portals that Finland uses in Box 6.1). Opinions can be given by those who have received a request, as well as by any other party who registers for the service. In practice, a request for comments is sent to known stakeholders and the text is published to allow members of the public to comment. The request may also be supplemented with a questionnaire (Ministry of Justice, n.d.[21]). A minimum of six weeks for a consultation and eight weeks for “extensive” projects is recommended by the ministry (Ministry of Justice, n.d.[21]). Shorter periods may be permitted, but need to be justified. The guideline states that submitted comments should be documented in relevant project documents such as reports by working groups, minutes or memoranda. For legislation, a summary of the relevant consultation and the comments received should also be presented in the relevant government proposal.
In practice, the ministry concedes that the use of its guidelines, which are not legally binding, is mixed across different ministries.7 On a similar note, the Office of the Chancellor of Justice – which considers oversight of public participation and transparency to be a priority area of oversight – conducted a review of the transparency of law preparation practices in 2020 and noted their “uneven” quality. Preliminary findings indicated that public consultations had not included open access to all relevant materials, and that they had sometimes been too short.8 In terms of impact, the OECD’s Better Life Index gives Finland a score of 2.2 for its stakeholder engagement in developing regulations (on a scale of 0‑4), which is slightly lower than the OECD average of 2.4 (OECD, n.d.[22]). This indicator measures the extent to which governments engage with stakeholders when developing primary laws and subordinate regulations, measuring “elements such as consultation methods, openness, transparency and feedback mechanisms” (OECD, n.d.[22]).9
In addition, the ministry has developed an accompanying Legislative Consultation Guide for public authorities, experts, organisations and companies (Ministry of Justice, n.d.[23]). This guide provides extensive practical guidance on planning, timing and methods. Ministries are advised to engage in a stakeholder mapping exercise at the outset to identify all those who have an interest or expertise in the matter under consideration, including other ministries, companies, executive authorities, advocacy organisations, municipalities and researchers. It stresses that the views of citizens and groups of citizens must be taken into account (Ministry of Justice, n.d.[23]). In order for the legislative proposal to reach as wide a range of stakeholders as possible during the preparation phase, it advises using multiple different methods and approaches as there is no “one-size-fits-all model” and certain methods are more suitable for certain groups.
The suitability of different fora and methods are then assessed in detail. For example, temporary multi-member preparatory bodies such as committees, commissions and working groups are recommended as being suitable for broad-based preparation of legislation. The guideline notes that in line with the Law on Equality between Women and Men, preparatory bodies must have both female and male members with a quota of 40% (of the minority sex), unless there is a specific reason for not doing so (Ministry of Justice, n.d.[23]). Stakeholder workshops should be used in the preparation and planning phase to engage in brainstorming, joint planning and problem solving. World cafés are suitable where there are up to hundreds of participants and where a full range of opinions need to be mapped. Participants are divided into small groups of six to eight people to discuss pre-determined themes and the ideas generated are recorded on “idea forms”. Citizens’ councils or juries are to obtain the views of particular groups (e.g., 12-24 participants) of the population on a certain topic. The working methods of these councils are facilitated group discussions, as well as joint reflections. When compiling such a council, the diversity of the jury (age, gender, background) should be taken into account. Traditional hearings, surveys and digital tools are also recommended for written feedback (see Box 6.1), in addition to social media channels for public communication. Furthermore, the guideline advises on when to consult stakeholder groups such as dedicated advisory boards, social partners, universities, churches and youth.
On handling feedback, the guideline advises that sufficient time should be set aside to consider opinions based on inputs received and that feedback should be documented in project documents (Ministry of Justice, n.d.[21]). Crucially, stakeholders and citizens should be communicated with openly about how the feedback has affected the further preparation of the legislative proposal and on what rounds any changes have been made, in addition to why proposals submitted cannot be implemented (Ministry of Justice, n.d.[21]). In addition, the implications of the feedback should be summarised in an explanatory memorandum attached to the legislative proposal.
The ministry works with a series of committees, working groups and advisory boards to ensure input from non-governmental actors into decision-making processes. One of these is the Advisory Board for Ethnic Relations (ETNO), a body of experts tasked with promoting dialogue and co-operation between different actors including migrant, cultural and religious groups, and to bring forth policy issues. This national-level advisory board comprises representatives from six ministries, nine parliamentary groups, two labour organisations, the Association of Finnish Local and Regional Authorities, seven regional advisory boards, and ten civil society organisations (CSOs). Other similar advisory boards that the ministry works with include the Advisory Board on Civil Society Policy (KANE), the Children’s Advisory Board, the Equality Advisory Board, the Consumer Disputes Board, the Legal Aid Board, and the Equality and Gender Equality Board. Alongside the development of the policy and legal framework on participation in recent years, there has been a shift in thinking within the ministry. It has moved away from a traditional focus on consultative committees towards a more “fit for purpose and pragmatic system of consulting committees for larger projects, and mixed working groups – where the pace of decision making tends to be faster – for smaller projects.10
Citizens’ initiatives in practice
As of October 2020, 39 citizens’ initiatives had been submitted to parliament out of a total of 1 178 submitted since the scheme started. Fifty-one of these were ongoing (i.e. signatures were being collected) and two were getting started or awaiting the collection of signatures (Ministry of Justice, n.d.[24]). Many of those submitted to parliament have had a potentially far-reaching societal impact. Areas of focus include preventing the privatisation of water supplies; ending deforestation of state lands; providing free secondary education; a referendum on membership of the euro area, and gender-equal marriage. A recent study noted that about 49% of all initiatives concerned three main policy areas: 1) health, welfare and housing, 2) civil liberties, civil rights, and law and order, and 3) government and political processes (Christensen et al., 2017[25]).
The system is popular and considered a relatively accessible method of participation, given that it is internet-based (via www.kansalaisaloite,fi) and involves no costs, although signatures may also be gathered on paper (Christensen et al., 2016[26]). In a further positive development, it has proven to be a testing ground for ideas and awareness raising “on questions that tend to be under-represented in the parliamentary decision-making agenda” (Christensen et al., 2016[26]). Initiatives have also helped to increase pressure to improve transparency within decision-making committees (Christensen et al., 2016[26]).
There are important nuances to this positive outlook, however. Research indicates that taking part in a citizens’ initiative may actually decrease trust in the process and that it is important to differentiate between the positive impact of the availability of citizens’ initiatives and the potentially negative impact of taking part in them (Christensen, 2019[27]). Nevertheless, when participants achieve their intended aims or if the process is seen as fair, trust in the process increases (Christensen, 2019[27]). As Bauer and Fatke point out, even when there are negative developments associated with citizens’ initiatives, the very fact of being able to participate in such a process may mobilise people and strengthen democracy (Bauer and Fatke, 2014[28]). This appears to ring true in Finland. While most Finnish initiatives are defeated in parliament, the democratic process that results is viewed as being very worthwhile by government, citizens and civil society groups alike (Christensen et al., 2017[25]). The government sees the Citizens’ Initiative as one of the state’s biggest achievements related to the promotion or protection of civic space at the national level in the past number of years (Government of Finland, 2020[20]). Some of the initiatives have marginal interest but two, in particular, led to significant changes in the law and were warmly welcomed by civil society groups: on same sex marriage and improved maternity rights for lesbian couples.11 Looking ahead, it is important to evaluate the service and to keep improving it and its accessibility, in line with citizens’ feedback and emerging needs. Research indicates that it has increased democratic inclusion in Finland, by attracting participation from younger Finns who may otherwise be politically inactive (Christensen et al., 2017[25]) (Huttunen and Christensen, 2019[29]). Support or incentives for targeted citizens’ initiatives from under-represented groups in society could support this conclusion.
There is a lack of related data to better understand how many local-level citizens’ initiatives and local referenda are taken to municipalities and how many are rejected and why.
Consultation via committees, advisory boards, working groups and other means
Interviews revealed a well-established system of government engagement with civil society and other stakeholders, via a wide range of committees, advisory boards, working groups, councils, hearings and digital fora. A strong tradition of trust and consensus-building frame this approach (OECD, 2010[30]). Non-governmental stakeholders are regularly invited to join these groups, or in the case of umbrella organisations such as the Finnish Federation for Social Affairs and Health (SOSTE), to nominate a member to join. SOSTE has more than 100 representatives in various government co-ordinated committees and working groups, as an example.12 However, according to CSOs interviewed government invitations to such groups are fewer than before.13 The following presents a snapshot of selected approaches and consultation methods being used by different ministries:
The Ministry of Environment is currently testing a number of methods and innovations to engage on reforms to the Climate Change Act, utilising a human-rights based, inclusive approach to consultation and working with a range of external partners.14 These include: an online survey in six languages (English, Swedish, Finnish and three Sámi languages), consultations in different cities with the public; consultations with stakeholders (e.g., municipalities, legal experts), consultations with youth during school time via the all-Youth project (All-Youth, n.d.[31]), dialogues with journalists and online chats with citizens; online discussions using the Timeout platform (Sitra, n.d.[32]), meetings with climate activists in small groups, hearings; and workshops with Sámi youth in Finnish and Sámi. In October 2020, human rights-related discussions were planned via the BIBU research project (BIBU, n.d.[33]). A working group led by senior civil servants in the ministry is responsible for the development of the legislation, which aims to have a proposal ready for parliament by mid-2021, after which there will be a public consultation on the text. In early 2021 more than 18,000 people contributed to a discussion on what climate policy measures they find fair and just. The Prime Minister’s Office also leads a roundtable on climate change “to create a common understanding and view of how Finland can make a just transition to a carbon neutral society by 2035”.15 The roundtable includes a wide range of interests and sectors, including youth, and meets up to six times per year to support the preparation and implementation of climate policy at the national level. The Ministry of Social Affairs and Health engages with different interest groups via projects, working groups, advisory boards and committees, based on the principles of openness and transparency.16 Hearings with different actors, including municipalities, healthcare organisations and labour market organisations, are held in the early stages of legislative development to understand different views. This is of particular importance in the context of ongoing social and healthcare reforms in Finland. Constant efforts are made to involve a variety of CSOs in conversations that affect them. Round tables are held to discuss thematic issues and dozens of temporary working groups follow the development of legislation, including five on social and healthcare reforms.17 The ministry also works through national advisory boards such as the national co-ordinating mechanism for the UN Convention on the Rights of Persons with Disabilities, the National Advisory Board on Social Welfare and Health Care Ethics, the Finnish National Youth Council Alliance, and the Advisory Board for the Rights of Persons with Disabilities (VANE). VANE comprises members of disability organisations, ministries, the Association of Finnish Local and Regional Authorities, academics, and human rights organisations. The ministry’s Advisory Board on Romani Affairs works on enhancing the equal participation of the Roma population in Finnish society involving 16 members, half of whom represent the Roma population and the other half a variety of ministries. The Council for Gender Equality is a parliamentary council that is appointed by the government that drafts proposals and statements on legislation and other measures affecting gender equality. It comprises members of parliament and several CSOs, including the Central Association for Men’s Organisations in Finland, the National Council of Women of Finland, the Coalition of Finnish Women’s Associations, and Seta (LGBTIQ+ Rights in Finland). Engagement with these groups is viewed as part of the ministry’s general strategy, goals and values.18
The Ministry of Transport and Communications engages with a variety of stakeholders such as trade unions, CSOs and private sector operators on legislative reforms, guided by the principles of openness, fairness, courage and co‑operation.19 Its communication guide notes that “we find out the different views by consulting everyone” (Ministry of Transport and Communications, n.d.[34]). Its Communications Policy Department is active in trying new methods and learning is disseminated organically within the ministry, which is relatively small. It works through fora that gather regularly to discuss pertinent infrastructure projects, for example. A dedicated forum meets once a month to discuss the development of a 12-year transport infrastructure plan. Stakeholder groups also gather on different topics. The ministry is active on social media, uses tools such as message walls where people can publish opinions remotely, and streams meetings live on YouTube. It uses several government’s digital tools (see Box 6.1) to receive opinions and statements from the general public.
The Ministry of Finance has innovated in a number of areas in order to engage Finnish citizens. It has teamed up with the Dialogue Academy, the Timeout Foundation, Sitra and the Ministry of Justice to undertake a series of COVID19-related “Finnish national dialogues” (formerly “lockdown dialogues”), with the aim of providing a forum for facilitated and constructive discussion about life in Finland during the pandemic, for example (Government of Finland, 2020[35]). The dialogues provide an opportunity for citizens to come together to share their experiences, enhancing understanding, and building trust in the country’s ability to steer through the crisis. These online discussions (160 in all) attracted 1 100 people from all over the country between April and June 2020 and were resumed in September with follow up dialogues on “Life after the lockdown” and will continue from March 2021 (OECD, 2021[36]).20 The dialogues were co‑ordinated by over 100 associations, municipalities and private sector actors who were all trained to ensure consistency of approach. Unlike typical hearings where a general invitation is issued to the public, a heavy emphasis was placed on diversity and engaging “ordinary” Finns, who would not otherwise be involved in such exercises.21 This was achieved by issuing personalised invitations to prospective participants through a wide network of groups and contacts. Participants included foreign residents of Finland, Finns residing abroad and a host of other atypical consultative groups such as convicts, prisoners on temporary release, relatives of mental health patients, teachers and sex workers. A summary of the findings is available online and was distributed to central government leaders and municipalities to inform their decision making (Timeout, n.d.[37]), as well as circulated by the organisers through their networks (Government of Finland, 2020[35]). How the data gathered will be used in future policy and project development by the organisers, including to find solutions to identified challenges, remains to be seen. So far, the findings have fed into a COVID-19 pandemic exit strategy and resilience report in addition to the OECD Open Government Strategy and governance policy guidance (Government of Finland, 2020[35]).
A cross-government approach to consultation has been adopted in response to the COVID-19 pandemic. Several online working groups have been established in this regard, including:
A working group tasked with preparing an exit plan chaired by the Ministry of Finance and the Ministry of Social Affairs and Health, involving at least nine ministries and the Prime Minister’s Office. An accompanying scientific panel and subgroup of “collective organisations” (such as the Central Organisation of Finnish Trade Unions, the Trade Union for the Public and Welfare Sectors, the Confederation of Finnish Industries, the Local Government Employers, and the Federation of Finnish Enterprises) were charged with submitting proposals on post-crisis management and reconstruction to the working group (Government of Finland, 2020[38]). The working group committed to consulting a range of non-governmental actors on its work, including the business sector, municipalities, CSOs and environmental organisations (Government of Finland, 2020[38]).
A working group to assess the economic impact of the COVID-19 pandemic and how to return to sustainable growth was established by the Ministry of Economic Affairs and Employment and the Ministry of Finance, engaging academics (Ministry of Finance, 2020[39]).
A working group mandated to ensure health security at border crossings was established by the Ministry of Social Affairs and Health, involving at least three ministries, the regional state administrative agency, the Transport and Communications Agency, municipalities, and regional administrative authorities (Government of Finland, 2020[40]).
Human rights organisations and others interviewed for this Civic Space Scan were complementary about the consultation process regarding COVID-19, while also expressing a number of concerns.22 They noted that some associations providing healthcare support, services, and children’s rights were consulted regularly, and that the Finnish Human Rights Centre and the Parliamentary Ombudsman had been consulted. For instance, one group was consulted on the status of undocumented migrants, including on reaching this group with multilingual information and fighting disinformation, an example of a particularly good practice.23 But they also called for more systematic consultation with organisations with general human rights expertise, and for more consultation on the long-term recovery (as opposed to the immediate response), as well as lessons learned during the pandemic. Some felt the level of consultation was less than could be expected and less than normal, due to an ongoing “emergency mentality”.24 Following the introduction of emergency measures in the early stages of the crisis, which affected the operations of some CSOs, some also found government guidelines on the reopening of activities and services unclear and incomplete.25 While there is faith in the current government to keep upholding democratic principles and norms and while cooperation between the government and CSOs worked well overall during the crisis, a concern was also raised about setting a precedent where during emergencies, consultation practices may become restricted.
Box 6.1 provides an overview of the main online channels, tools and opportunities to make government more open, transparent, participatory and inclusive in Finland.
Box 6.1. Digital tools for e-participation in Finland
www.otakantaa.fi: The “have your say” website allows both public officials and members of the general public to have interactive discussions. This site is intended for use during law-drafting processes to collect citizens’ views and map their needs using different tools such as polls, surveys and chat forums. It can also be used during monitoring and evaluation phases.
www.demokratia.fi: The democracy platform allows citizens to discuss and keep track of legislative projects, take part in discussions and consultations with public authorities on issues in Finland and the wider European Union, and take initiatives to parliament and municipal authorities. It includes links to all other participation portals.
www.kansalaisaloite.fi and www.kuntalaisaloite.fi are portals for the electronic collection of signatures for citizen initiatives at the national and municipal levels.
www.lausuntopalvelu.fi: The “opinion service” is a service for responding electronically to an official request for an opinion or statement during a law-drafting process.1 Opinions can be given by those who have received a request for an opinion, but also by all interested parties who register for the service.
https://kerrokantasi.hel.fi/?lang=en: The “voice your opinion” portal is run by the City of Helsinki. It invites citizens to “join us in developing the city and participate in open hearings”. Users can see and comment on the opinions submitted, which are summarised for decision makers. A summary of opinions received on different issues can be downloaded from the website.
www.exploreadministration.fi: This service maintained by the State Treasury provides access to budgetary and personnel information on municipalities and the central government.
www.nuortenideat.fi: The “youth ideas” service is dedicated to young people and those who work with them. It offers a “low threshold” tool for participation, influencing and expressing opinions. It aims to support co-operation between youth and municipalities, organisations, and educational institutions.
https://tutkihankintoja.fi/?lang=en: The “OpenProcurement” service provides citizens and companies with information on state and municipal-level procurement and how public funds are spent. For companies, the service provides information on current market conditions.
https://tutkibudjettia.fi/etusivu: The “ExploreBudget” service provides an opportunity to examine the state budget under different thematic areas.
The https://www.kokeilunpaikka.fi/en experimental platform offers the opportunity for people to roll up their sleeves, share an experiment, find partners, receive peer support, apply for public funding and implement their experiment.
1. The website notes that all public authorities can publish requests for opinions and that all organisations and citizens may submit these through the website.
Municipal-level participation practices
During the 2000s, novel modes of direct participation have emerged at the municipal level in Finland (Government of Finland, 2020[20]). An examination of these is particularly instructive, as the local level is often the testing ground for innovations and related decision making also has a direct impact on people’s lives. Furthermore, municipal-level survey data illustrate their increasing popularity. Research findings published in 2016, based on survey data, showed that while two out of three residents considered municipal elections to be the best way to influence decision making, more than half felt that a municipal referendum should be held when deciding on the most important local issues and eight out of ten respondents had used at least one method of participation or influence, whereas less than one-fifth had not used any (Pekola-Sjöblom, 2016[41]). The most frequently cited methods of participation that were used were answering a customer or user survey and participating in the activities of an association or organisation (Pekola-Sjöblom, 2016[41]).
Over the last ten years, there have been various examples of national-level experiments and innovations such as the crowdsourcing of ideas and the use of civic councils. A civic council held in 2013 considered how Finnish democracy could be strengthened, and its findings fed into the 2014 Democracy Policy Report (Christensen et al., 2016[26]). The Ministry of Environment and the Committee on the Future crowdsourced ideas for the Off-Road Transport Act in 2013 using an online platform, which were used in the preparation of the act (Christensen et al., 2016[26]). Today, municipalities are active partners and financial supporters of CSOs in local communities and engage with citizens in a wide variety of one-off or repeat fora (Table 6.1). As discussed earlier, they also have permanent councils for ongoing consultations, specialised boards (e.g. school boards) and customer councils (e.g. to involve citizens in service design). Belief in the effectiveness of these methods leans towards the positive, without being very strong (just over 3 on a scale of 1-5 between 2008 and 2017, where 5 represents a high level of satisfaction), but is at a marginally higher level than ever before (Meklin et al., 2020[42]). Both the use of these means of influence and the belief in their effectiveness is found to be strongest in semi-rural and small municipalities with fewer than 5 000 residents and weakest in more urban municipalities and cities with a population of more than 100 000 (Meklin et al., 2020[42]).
Table 6.1. Typology of selected participation initiatives at the municipal level in Finland, 2020
Source: Author’s own based on Christensen et al. (2016[26]) and updated with City of Espoo (n.d.[44]), City of Vanta (n.d.[43]), City of Oulu (n.d.[45]).
Participatory budgeting is relatively new and small-scale in Finnish municipalities, compared with other European cities (Kapanen, 2020[46]). Most initiatives have taken place in the greater Helsinki area to date, although other smaller projects have been organised in cities including Tampere, Espoo, Turku and Vantaa. A 2019 publication documented 15 such initiatives in 10 municipalities and noted that the number was rising each year in addition to the budgets (Ahonen and Rask, 2019[47]). It also found that about 12% of municipalities (22 in total) had used this method in 2017 (Ahonen and Rask, 2019[47]). According to the latest research from the Association of Finnish Local and Regional Authorities from 2020, 25% of municipalities that answered a questionnaire in August 2020 were using participatory budgeting, 17% were planning to use it, and 58% were neither using nor planning to use it (Association of Finnish Municipalities, 2020[48]).
OmaStadi is Helsinki’s participatory budgeting project, with EUR 8.8 million for residents to decide how to spend in 2020-21 (Municipality of Helsinki, n.d.[49]) (Figure 6.2). The following are among the criteria guiding the submission of OmaStadi ideas and projects: they must comply with Finnish law and the city’s values and strategy, they must be within the city’s power to implement, and they must not contradict an existing zoning plan or decision. The cost must be at least EUR 35 000 while not exceeding half of the total funds allocated to the district in question (City of Helsinki, n.d.[50]). Ideas for the project were submitted in 2020 and will be developed into proposals and budgeted for during a series of co‑creation workshops in 2021, then voted on by all residents turning 12 or older during the year. In 2022, the most popular ideas will be realised by the city. The initiative is viewed as being successful so far, although measures for supporting the participation of marginalised groups could be improved (Rask et al., 2019[51]).
Figure 6.2. City of Helsinki’s OmaStadi participatory budgeting project
Source: City of Helsinki.
Tampere is also experimenting with crowdfunding (discussed in Chapter 5) and participatory budgeting. As part of the Mun Tampere Participatory Budgeting, residents are able to innovate, plan and decide how to use EUR 450,000 to promote the well-being of children and young people. The project is open to anyone, regardless of age or residence. It started with an “ideation phase” from 15 April to 15 May 2020 to gather ideas and share them online.26 In August and September 2020, the city undertook workshops to develop the ideas with residents and develop budgets for them. Voting was ongoing for projects as of November 2020.27 The twelve most popular initiatives will be implemented in 2021. The main objective of participatory budgeting is to “increase the sense of inclusion” in the municipality, by co-operating with all citizens, based on a realisation that such initiatives have the potential to make a real difference to people’s sense of belonging.28 Tampere has a history of trying out new initiatives, and there is a growing interest among City Council leaders to develop new opportunities for citizens to engage.
As Tampere experiments and opens up to inputs from the public, it is having to grapple with what is an increasingly common challenge in Finland: choosing how to engage with associations that espouse discriminatory views and practices.29 This has become a key issue for many of Finland’s larger municipalities. The case study in Box 6.2 illustrates the potential for municipalities to successfully use ethical frameworks to ensure that publicly funded activities and initiatives conform to national legal frameworks and values, as Tampere has done. Public libraries, sports facilities, town halls and any other publicly funded spaces are all facing the same issue and guidance on how to address this complex area, while remaining within the confines of the law, is needed as a priority. The Ministry of Justice or Ministry of the Interior could usefully develop a general ethical framework to guide municipalities in this regard, thereby helping to ensure consistency and procedural fairness in decision making and pushing municipalities to act in defence of equality and a free and open civic space.
A particular challenge in this respect is related to the fact that associations ostensibly engaging in sporting, humanitarian or “patriotic” activities (even those espousing neo-Nazi ideologies), may be officially registered and therefore have the legal right to exist.30 While the number of people involved in these groups is extremely small, they may be members of multiple, interlinked associations of this nature, with the result being that they have a disproportionate impact at the local level.31
Box 6.2. Case study from Tampere: Using an ethical framework to combat discrimination
In 2019, the municipality of Tampere used an ethical framework governing the rental of premises for culture and leisure to justify denying Suomalaisapu ry (“Finn Aid”), a CSO associated with the neo-Nazi Nordic Resistance Movement (NRM), to participate in the Citizens' Advocacy Day organised by the city. This was before the Supreme Court had confirmed the NRM’s ban. When the organisers noted that Suomalaisapu ry had registered, they approached the police to evaluate the case. The police were unable to comment on an active investigation1 but urged the city to consider including the association in the event, in support of freedom of expression (City of Tampere, 2019[52]). A detailed study of the application involving the city’s lawyers and a number of members of staff was subsequently launched, including because other participants in the event objected to Suomalaisapu ry’s involvement.
After it was established that there were indeed close links between the organisation and the NRM, the application was assessed against the city’s ethical principles for rental of premises (which had been developed by the City Council in 2018).2 These state that the city “strives to promote equality in its activities, to prevent discrimination in all its forms and to address perceived or reported discrimination” (City of Tampere, 2019[52]). The application was also assessed against the recommendations of the National Action Plan for the Prevention of Violent Radicalisation and Extremism 2019-2023 (Ministry of the Interior, 2019[53]). This plan advises that premises maintained through public financing should not be “used for activities whose aim is to promote confrontation between different population groups and instigate people to hate and violence” (Ministry of the Interior, 2019[53]). The case proved to be a difficult one for the City of Tampere in terms of finding a solution while fully respecting related legal frameworks and guidance.3 It was obliged to act within the confines of Chapter 2, Section 6 of the Administrative Procedure Act, which states that:
An authority shall treat equally those to whom it is providing services in administrative matters and shall exercise its competence only for purposes that are acceptable under the law. The acts of an authority shall be impartial and proportionate to the objectives sought (Ministry of Justice, 2003, latest amendments 2015[54]).
This requirement to treat all parties equally is also linked to Article 6 of the Constitution, which states that people are equal before the law (Ministry of Justice, 1999, latest amendments in 2018[3]).
Following an official complaint by Suomalaisapu ry to the Parliamentary Ombudsman about the incident, the City of Tampere responded in a formal submission to the Ombudsman. It argued that the principle of equality requires equal treatment, but when interpreting and applying this standard, public authorities must treat similar cases in the same way, while also taking into account their differences (City of Tampere, 2019[52]). Equal treatment requires a “case-by-case assessment therefore that takes due account of the specificities of each case” (City of Tampere, 2019[52]). The Office of the Parliamentary Ombudsman has since responded to the City of Tampere in support of its decision.4
Tampere learnt from the experience in 2019 and in 2020 when the city was organising a similar event on a portal (Artteli, n.d.[55]), it communicated its ethical principles, which have become institutionalised, during the registration phase for the event. These principles clearly state that events must be free from racism and discrimination and that every association or community involved in the activities undertakes to respect the Constitution and related human rights guarantees (Artteli, n.d.[56]). Furthermore, activities should work to reduce discrimination and increase community spirit, security and strengthen the involvement of citizens (Artteli, n.d.[56]).
1. In April 2019, the Central Criminal Police had launched a preliminary investigation into whether the NRM continued to operate despite the ban (City of Tampere, 2019[52]).
2. A very brief ethical approach statement had been developed by the city in 2010 and expanded and updated by the City Council in 2018, as a response to what was perceived as a growing need
3. Email, City of Tampere, received 24 November 2020.
4. Interview, City of Tampere, 27 November 2020.
Research from Jäske on participation initiatives at the municipal level is particularly instructive, offering insights on a range of issues that are highly relevant to national-level initiatives (Jäske, 2018[4]):
A study of whether democratic innovations i.e. focus groups, citizens’ initiatives, town hall meetings, referendum motions, local area councils, surveys, feedback forms, online comments on local council agendas, surveys via phone or email, and advisory referenda could potentially mobilise people with low levels of political trust found that such methods were most likely to mobilise those who already trusted the government. However, it also found that personal interactions or face-to-face methods can be effectively used to reach out to less educated people and those who are not associated with political parties, whereas online methods tend to be more popular with “people with a partisan identity”. This resonates with the finding elsewhere in the Scan that personal communications with citizens can increase participation levels.
A separate study investigating whether the number and type of participation initiatives affects people’s perceptions of their fairness and resulting levels of satisfaction found that numbers do not matter, but that the type of methods used does. It revealed that “discursive participation possibilities” i.e. discussions, participatory planning, hearings, citizen juries, panels may have a positive effect by giving people a sense of being listened to, whereas “purely consultative forms” i.e. surveys, polls had the opposite effect.
Innovation and experimentation to promote and strengthen participation
Finland has a strong commitment to experimentation, foresight and innovation and should continue to tap into this to develop new methods and improve existing ones to channel citizens’ views into public decision making. The current government programme has an explicit commitment to continuous learning and experimentation in government, in addition to research, development and innovation and includes a target of spending 4% of gross domestic product (GDP) on this area by 2030 (up from 2.8% currently) (Government of Finland, 2019[12]). Finland has a portfolio of ongoing public sector experiments at the national level (Nokso-Koivisto and Kaskinen, n.d.[57]; Demos Helsinki, n.d.[58]). As an example, the government’s www.kokeilunpaikka.fi (“experimental site”) digital platform offers Finns an opportunity to support the public sector goal of creating an experimental culture to find innovative ways to develop public services. The platform offers an opportunity to foster innovations; market them; collect feedback, advice and funding; and connect innovators with government reformers. A recent call on the website invited experiments that provided “new climate solutions” at the municipal level. A total of EUR 100 000 has been reserved for the implementation of the experiments with the Ministry of Environment offering to fund each selected experiment project with EUR 10 000.
Deliberation is an area of innovation that is currently underutilised in Finland and has the potential to be used more, including to discuss and build a consensus on divisive political issues. The OECD’s Innovative Citizen Participation and New Democratic Institutions: Catching the Deliberative Wave report identifies these as one of the most innovative methods of citizen participation, “reintroducing the Ancient Athenian practice of random selection (sortition), updated with modern statistical methods that allow for stratification” (OECD, 2020[59]). This focus on representativeness can yield processes that complement representative democracy and “improve the democratic process more broadly” (OECD, 2020[59]).
There have been few deliberative citizens’ panels/juries or mini publics based on random sampling to date and most of these have been led by academics. Examples include:
a national policy-related mini-public on challenges to Finnish democracy in 2013 commissioned by the Ministry of Justice and organised by Centre for Consumer Society Research at the University of Helsinki
three experimental mini publics on nuclear energy, immigration and the status of the Swedish language respectively, organised by three universities (the Åbo Akademi University, Tampere University and the University of Turku)
two policy-related mini-publics on the question of municipal mergers in Korsholm and traffic planning in Turku, also by the Åbo Akademi University.32
A study on the Korsholm example found that mini-public-type processes “can help provide trustworthy information that help voters make informed and reflected choices in polarised top-down referendums” (Setälä et al., 2020[7]). A separate study on a deliberative exercise on immigration (using data from 2012) concluded that “[D]espite the mixed results, we are cautiously optimistic about deliberative democracy’s potential to reduce misperceptions.” Based on the Finnish experience, it noted that “inclusive and diverse deliberative settings seem particularly beneficial for decreasing misperceptions”, as suggested by the literature on the subject (Himmelroos and Rapeli, 2020[60]). At the municipal level, cities have engaged in deliberative citizen juries in interesting ways – not necessarily involving academics – but not using random samples. Recruitment has tended to be based on self-selection via open calls published by media or through targeted recruitment drives.33 Topics addressed have included the use of wind power, urban planning, social services and transport policy.34 For this reason, the national-level Citizen’s Panel on Freedom of Expression commissioned by the Ministry of Finance and the Ministry of Justice as part of this Civic Space Scan is an example of a new and exciting innovation with great potential for learning across ministries. It is based on a random sample and provides citizen recommendations on the concrete policy question of what the government can do to better protect public figures from harassment and hate speech (Box 6.3).35 Based on the views of a microcosm of Finnish society, it has particular legitimacy. There is also significant potential for learning from this exercise, including for the Citizens’ Panel planned by the Ministry of the Environment in April 2021.
Box 6.3. Finland’s Citizens’ Panel on the Freedom of Expression
The members of the Citizens’ Panel drew up the following collective public statement and made 25 recommendations:
“We, the members of the Citizens’ Panel, consider the following objectives that have guided our work and the formulation of recommendations important. Work to combat hate speech and online shaming, should first aim to make hate speech visible to the public, so that it will be clearly condemned and denounced. It is also very important that definitions for hate speech and online shaming are clear and that they are communicated to the general public. Judgments on hate crimes and harassment must be sufficiently compelling, but at the same time, efforts should also be made to prevent hate speech and online shaming. Authorities and organisations must have sufficient resources for the work. The responsibility and regulation of online platforms that enable the problem should be increased.”
Resourcing and coordination
1. Establish a “Trusted flagger”-type organisation, which could report hate speech when it occurs.
2. Give hate speech and online shaming an official definition and implement and share this.
3. Give clear responsibilities in the work against hate speech and online shaming to individual persons in central government (e.g. Minister of Equality) or to an organisation.
4. Give, for example, the police, courts and media increased resources and certain powers.
Legislation
5. Review the penalties given for hate crimes, specify them in legislation and define stricter minimum penalties. Add to legislation that hate speech targeting gender, ethnicity or a minority group will be punished more severely.
6. Examine the possibility of using community service as a penalty for hate crimes.
7. The classification of offences related to hate speech will be made clearer.
Guidelines for employers and those working in public professions
8. Employers will be obligated to draw up clear instructions for possible cases of hate speech or harassment, both in order to intervene in the situation and to support the victim. These instructions must be designed to suit each work environment and must ensure the smooth functioning of the support network for the process in the workplace.
9. Draw up specific guidelines for decision-makers and those officials most susceptible to online shaming, if they themselves are victims of hate speech and/or harassment. Produce an advance information package for people in public posts in case of online shaming and hate speech.
10. Ensure that people in all organisations who suspect they are a victim of hate speech have the opportunity to communicate a message to a party, such as an occupational safety representative, who can assess whether the person has been subjected to hate speech and give recommendations on further measures. Ensure that this is also implemented for decision-makers and that sufficient resources are available for it.
Legal protection of victims
11. A “Track my case” system will be created in which the victim can personally monitor the progress of his or her criminal case in the judicial process and obtain information on when decisions can be expected.
12. A website provided by authorities will be established detailing all support services for victims of hate speech and online shaming, including a support network and peer support for victims of online shaming and hate speech. If necessary, an authority can direct a victim to the website.
Communication and training
13. Increase effective communication to citizens on the subject area. A sufficiently long information campaign on hate speech and online shaming and their criminal sanctions intended for citizens will be carried out utilising good experiences such as those of communication on the coronavirus.
14. Increase training on the identification of hate speech for different professional groups and authorities (judges, the police, and prosecutors). Training must be provided on combating and preventing hate speech to a wider audience, for example through comprehensive school, conscription, non-military service training and national defence courses.
15. Develop our culture of dialogue and increase the participation of minorities in public debate.
Attitudes of social actors
16. The ministries will draw up a code of conduct for decision-makers and officials. Denouncing hate speech and discrimination should already be a criterion for nomination in elections. Reacting as early as possible to election interference and interference attempts by means of hate speech and online harassment.
Civic participation
17. Develop ways in which citizens can influence decision-making in advance. Prepare guidelines, protocols or methods for requesting comments in advance. Change the way in which decisions are made, ensuring that citizens have an opportunity to participate in decision making before actual decisions are made and after decisions are made.
18. Listening to citizens better in decision-making by organising citizens’ panels on current issues at the municipal and state level.
Research
19. Increase regular and continuous research and review of hate speech. Research will aim to give a more specific definition for hate speech. Increase resources for the research of new phenomena and challenges.
Responsibility and regulation of online platforms
20. Ensure that online platforms operating under Finnish jurisdiction have at least one person personally legally liable for the material published on the platform (c.f. editor in chief for newspapers). Obligate platforms to make available their rules for discussion.
21. Draw up common, purposeful and transparent rules and recommendations based on human rights for online discussion platforms. Ensure that discussion platforms accept and commit to these. Create a certificate for actors that comply with good practices (c.f. smiley face used by restaurants).
22. Create a counterforce for internet trolls. Bring trained influencers, who condemn hate speech and trolling (so-called “social media agents” or “anti-troll army”) to different online platforms, where they will encounter hate speech and those spreading hate speech and tell them directly that hate speech is not permitted.
23. Emphasise corporate responsibility and create incentives for social media companies. For example, develop an algorithm that would prevent filter bubbles. Also encourage intervention in anonymous online discussions, an improvement to advance moderation and training of moderators.
24. Encourage citizens to take part in the moderation of internet content, and encourage companies to develop user moderation.
25. Influence EU legislation and EU negotiations with “digital giants”.
Source: Citizens’ Panel Final Report (Jäske et al., 2021[61])
Learning from the OECD’s After Shock Event on 17-18 November 2020, which involved more than 65 local events and more than 5 500 people joining forces to discuss public sector lessons from the COVID‑19 pandemic, seems particularly relevant to a discussion about innovation and experimentation in relation to civic space in Finland. A key conclusion from the global event was that governments must embrace and explore uncertainty in the face of complex future (OECD Observatory of Public Sector Innovation, n.d.[62]). A summary report noted that:
“… governments need to deliberately engage with and explore uncertainty to be better prepared, resilient and steer towards preferred futures. New approaches have emerged in this space, including anticipatory innovation governance, strategic foresight, and methods for experimentation and deep listening amongst others that deliberately engage with uncertainty” (OECD, 2020[59]).
Finland has performed remarkably well so far in response to the COVID-19 crisis and has a unique focus on foresight and preparedness in the public sector (OECD, 2021[36]). As such, it is better placed than most countries to meet the challenges ahead. As the government continues to steer the country through the crisis, it is key that it promote the conditions for continued innovation and experimentation, combined with a holistic focus on preparedness for the future that is sustained by a healthy civic space.
Challenges to participation practices and recommendations
Finland’s ongoing efforts to engage with its citizens and enhance opportunities for meaningful engagement is commendable. However, a number of challenges in relation to the implementation and quality of ongoing efforts emerged during the interviews undertaken for this review and are discussed below.
Moving towards a consistent, co-ordinated, and transparent approach to consultation and engagement with civil society actors
At the national level, the frequency and quality of consultation and engagement practices varies across ministries and this changes from government to government. None of the ministry interviewees referenced the Ministry of Justice consultation guidelines during interviews, for example. The lack of uptake of government guidelines on effective consultation practices was highlighted by the OECD in a 2010 report on regulation in Finland, which noted the “very different and uneven performances on consultation among ministries” (OECD, 2010[30]). Interviews indicate that this remains a challenge, resulting in what appears to be a siloed approach. Finland could, therefore, take measures to ensure the Ministry of Justice guidelines are routinely followed to ensure best practice across all ministries. In particular, CSOs want to be consulted on legislation, proposals and issues that affect them early in the process, in order to be able to influence them.36
Invitations for non-governmental actors to participate in different fora are viewed as being erratic and subject to the political views of the government of the day.37 The trade unions are more valued by left leaning governments, for example, and diverse types of CSOs and umbrella groups representing particular interests may be favoured at different times. Furthermore, invitations often favour bigger and more powerful, traditional organisations and unions.38 While some legislative reforms, such as for the Money Collection Act, are considered to have been very inclusive, many smaller, often voluntary organisations often feel left out of processes. Two large umbrella organisations, SOSTE and Fingo, complained about their members being excluded from key decision making. SOSTE noted:
“There have been several occasions, in which social and health NGOs have been left out of most important committees and working groups, although in these very groups decisions are made concerning, for example, the funding processes and other operating conditions crucial to NGOs.”39
The Finnish League for Human rights lamented the different consultation standards among the ministries and the fact that it is not consulted on crucial issues such as Sámi lands and rights in relation to mining issues.40
Finland could also improve transparency and consistency in relation to its choice of consultees by institutionalising practices across ministries (OECD, 2010[30]). Currently, there is no cross-government approach or criteria for inviting stakeholders to join the different consultation groups and no cross‑government data available on which groups are selected for what purpose and why.41 A centralised portal or webpage to show this information could help to move away from the long-held practice of conducting consultations with organised groups of stakeholders, based on traditional power structures and personal relationships, towards a more transparent and inclusive approach to smaller and newer actors. Furthermore, it could help to avoid conflicts of interest, the over-representation of certain groups in multiple fora and politicised appointments. Quotas for CSO representatives on advisory boards and in other participation fora would also help to ensure that the non-governmental perspective is adequately represented. As discussed above, some of the advisory boards such as the KANE and also ETNO have surprisingly few CSO members. In 2019, the Council of Europe noted that ETNO only partially fulfilled its mandate as an effective consultative mechanism, for example, noting that “neither its role in the political decision-making process, nor its selection and appointment procedure appear to be regulated in a sufficiently precise manner or known to all minority representatives” (Council of Europe, 2019[63]). It advised an overhaul of ETNO’s composition given that minorities themselves constituted a minority among its members.
Ensuring better feedback and documentation of decision making
Early consultations with reference to what to consult civil society on as well as what data to share, would facilitate more open processes. When CSOs are consulted, their views are sometimes treated by the government as coming from a homogenous group, when in fact they represent a multiplicity of views.42 This is exacerbated by the fact that there is often little clarity and documentation on how decisions are taken following or during a consultation process. The Ministry of Justice is aware of this challenge, including the need for better feedback loops on how decisions are reached based on different positions, and more transparency through documentation.43 Acknowledgement of different non-governmental viewpoints, routine sending of revised drafts to organisations consulted before uploading them to the relevant portal, and publishing tracked versions of documents could help to overcome these difficulties. Monitoring of how inputs from civil society are used by government ministries or other entities (or not) would also be beneficial, both for the government and civil society actors. The Ministry of Finance’s publishing of tracked changes to its 2019-2023 Open Government Action Plan on its open government website is commendable (Ministry of Finance, n.d.[64]). Regarding Finland’s participation in the Open Government Partnership, the government has a multistakeholder forum comprising several government-civil society groups and illustrating a commitment to engaging CSOs and citizens, learning from their inputs, and collaborating on the implementation of shared objectives (Box 6.4).
Box 6.4. Finland’s Multistakeholder forum
The Open Government Partnership (OGP) provides a platform for government leaders and civil society advocates to create a unique alliance to advance accountable, responsive, and inclusive governance. The OGP was founded in 2011 and currently comprises 78 countries and 20 local governments, with Finland joining in 2012. Finland is currently on its fourth action plan for the 2019-2023 term, which focuses on four core commitments: 1) lasting openness, 2) developing an open government strategy, 3) establishing a transparency register, and 4) improving open data.
In order to participate in the OGP, governments must exhibit a demonstrated commitment to open government by meeting a set of minimum performance criteria across key dimensions and prioritise the participation of civil society actors alongside government counterparts in the design and implementation process of their objectives. The OGP suggests that members establish a multi-stakeholder forum to facilitate this collaboration and encourages members to develop these processes beyond its minimal requirements, through a long-term institutionalised mechanism for open dialogue.
Finland has a strong commitment to its multi-stakeholder forum, which comprises several groups: KANE, the Civil Servants Network and Executive Committee, the Local Democracy Network of Municipalities, and the Open Government Team and Support Group. These groups have varying advisory, oversight, and decision-making mandates during the different phases of the OGP process.
Finland completed 5 of its 7 commitments in the third action plan (2017-2019) with inputs from its forum. These commitments focused on widening access to information, enhancing inclusive participation, more clear information on government activities and reforms, strengthening open government literacy of public officials and publishing procurement data.
However, the most recent Independent Reporting Mechanism report on Finland from 2017-19 demonstrated that some action plan commitments were only partly implemented in co-operation with civil society and the public, with the extent of the cooperation not increasing since the previous term. In addition, none of the 7 commitments were fully implemented in collaboration with civil society through the multi-stakeholder forum. Furthermore, it noted that the government gave feedback on how public inputs on the commitments were considered but did not establish an iterative dialogue that allowed the public to set the agenda from the outset.
The report also stressed that the Finnish government could ensure that the non-governmental members of the forum are selected through a more transparent and equitable process as currently members of several of the groups are chosen based on their expertise rather than by an open call. It added that some improvements are currently in progress that could allow Finland to achieve a higher standard, for example, by enabling more collaborative mandate development on the forum’s remit, membership and governance structure going forward.
Source: Finland National Action Plan 2019-2023 (Government of Finland, 2019[12]), Multistakeholder forums: Collaboration is the Cornerstone (Open Government Partnership, 2021[65]), Designing and managing an OGP multistakeholder forum (Velasco-Sánchez, 2021[66]), Independent Reporting Mechanism (IRM): Finland Implementation Report 2017–2019 (Laulainen, 2020[67])
Promoting cross-learning opportunities and impact evaluations of consultation and engagement methods
A structured initiative to share learning from the use of different practices and tools across ministries and from municipalities to ministries would help to ensure high standards, engage those that are less open to consultation, and avoid different actors from reinventing the wheel. Such learning could help to motivate ministries that do not have a strong record on participation towards cross-government standard setting in this area. Furthermore, it would allow learning from ministries with more experience to filter across the administration in a dynamic manner as methods and innovative practices develop. A regular discussion forum could be complemented with impact evaluations of different tools, consultation methods and experiments with partner organisations to begin to understand what delivers value, including value for money in relation to investments of resources, desired impact, representativeness and levels of satisfaction among those who participated.
Additionally, the outcomes of different participation processes are viewed by CSOs as varying, ranging from tokenism to high-quality participation with impact, and sometimes as high-quality participation but with little impact.44 Understanding the recipe for delivering high-quality participation with high impact across different ministries by undertaking regular impact evaluations could help to remedy this and to avoid poor quality participation methods, or poor quality execution, from being repeated.
Ensuring quality and accessibility of (digital) participation methods
The increasing tendency towards digital consultation, including because of COVID-19, also runs the risk of exacerbating inequality. The former President of the Supreme Administrative Court, Pekka Vihervuori, expressed his concern about the effects of information technology on law-making in a recent speech. He noted that an online portal for gathering opinions would certainly streamline and structure consultation procedures in the drafting of legislation, but that providing an opinion via the narrow question options on offer and “either/or” responses was inappropriate for his office.45 CSOs were also keen to convey that workshops and digital conversations should not replace “official participation in committees and working groups”, which allow for long-term, direct and higher quality interaction with government authorities.46 The digital divide presents an additional challenge, even in a country as digitally advanced as Finland. It is important to ensure that a variety of consultation tools, both digital and non-digital, are consistently made available to people to overcome this and that digital tools are designed to allow people to express themselves in full. A further, much more challenging area of concern is the ease with which issue-based campaigns can be organised on line to derail or take over online discussions on particular issues, thereby heavily skewing debates in one direction or another. Again, this highlights the need for different channels to be used. Finland could additionally learn from some of Italy’s approaches to find ways to strengthen digital participation (Box 6.5).
Box 6.5. Strengthening the quality of participation and related public sector competencies in Italy
Italy has developed a platform to improve citizen participation at various levels, with a particular focus on the central level. Modelled on Decidim, a free open-source participatory platform for cities and organisations that was launched by the Barcelona City Council in 2016, the ParteciPa website (https://partecipa.gov.it) invites citizens to engage in consultations on a range of policy areas, strategies and broad thematic areas such as agile and “smart” public administration and simplifying public sector bureaucracy. It offers a range of ways to participate: by making proposals, taking part in debates, prioritising projects to implement, attending face-to-face meetings and other actions. Since its launch in 2019, the platform has been used to hold eight separate public consultations.
From the government’s perspective, civic participation enhances its capacity to hear from and balance the concerns of a range of interested persons and affected parties. Furthermore, ParteciPa aims at “enabling the various public institutions to open their participation processes to citizens and to create spaces for collaboration in co-designing public policies in a coherent manner”, as well as ensuring the quality of participatory processes. It also helps the institutions concerned to be more accountable and transparent, as all of the activities carried out within each citizen participation process are public, with relevant data and content made available as open data.
In line with the European guidelines for e-participation, at the end of each consultation or participation process, a report on the main results should be provided (European Union, 2012[68]). The aim is to guarantee feedback to all participants and to provide evidence on the impact of the participatory process, although this has proven to be the most difficult aspect for the Italian administration to implement in practice. Related learning includes the need to allow enough time and resources to provide the necessary feedback on how inputs were integrated into decision-making processes from the planning stage.
A second government objective is to create a “competence centre” for the public administration, in line with Action 4 of Italy’s National Action Plan for Open Government 2019-21.1 As such, the ParteciPa website and a separate one-stop website offering opportunities to participate in regional-, commune- and ministry-level consultations (http://consultazione.gov.it/it) are contributing to:
The dissemination of information about online consultations and participation processes promoted by governmental organisations at all levels (central and local).
Establishing a network of civil servants who are skilled in participatory processes and who can help others setting up similar processes.
Creating a repository of handbooks, guides, toolboxes, examples and best practices with a view to shared learning. A forthcoming guideline for online public consultation will combine basic concepts, principles, tools and concrete examples of good practice.
The overall aim is improve participation in decision- and policy-making processes by giving support to public administrations wishing to organise online consultations and by improving public sector skills in relation to the use of technology and online tools.
1. Email, Government of Italy, 16 December 2020.
Source: Email, Government of Italy, received 16 December 2020.
Moving beyond consultation and engagement with the usual suspects to engaging the general public
Finland is in a particularly strong position to continue to protect and promote civic participation and civic space more broadly via its Open Government Strategy and longstanding national open government agenda, in addition to its initiatives related to strengthening democracy and civic freedoms, and its current government programme. While there is broad enthusiasm for engaging citizens more in decision making, there is also disagreement regarding how and the extent to which this should happen. A focus on ensuring the quality, representativeness and legitimacy of participation efforts is probably wisest.
As municipalities experiment with new participation methods for the general public, it is important to target and engage marginalised and typically under-represented groups in society, particularly in bigger urbanised municipalities and cities. Seeking to move beyond engaging the usual “stakeholders” and more active, better educated, self-selecting members of the public is key and will require strategies, conscious decisions, and targeted outreach. Regular impact evaluations of such initiatives, in relation to participants’ perception of inclusion and sense of being listened to, would help to shed light on deficiencies. Crucially, new forms of participation offer citizens the opportunity to have an impact on decision making, but can also shape their attitudes towards authorities, decision making and democracy more generally (Christensen et al., 2016[26]). The stakes are, therefore, high, and perceptions of “procedural justice” or fairness – in terms of being listened to and views being taken on board – are central (Christensen et al., 2016[26]). Fairness is also important in a broader sense in order not to exacerbate existing inequalities. A recent study notes that participatory budgeting has been criticised for its unfair implementation in different locations, with the same amounts of money allocated to different areas but money in one case going to fund basic infrastructure and in another to fund a golf course (Ahonen and Rask, 2019[47]).
Learning from the Finnish national dialogues indicates that sending personalised invitations to members of the general public i.e. those not involved in advocacy, interest groups or associations; less educated people who may feel they have little to say; people who may ordinarily be too busy or too intimidated to join discussions to participate is an effective way of engaging them. A related effort to ensure that participation opportunities provide “safe spaces” for people to express their views as part of constructive discussions is also important, and can be achieved with trained facilitators. As discussed above, personal interactions and more discursive methods may also yield better results than surveys or other one-way consultation methods do. Evaluations of participation initiatives to assess participants’ (and sub-groups of participants’) perceptions of being listened to, could help to shed light on areas for improvement. Providing accessible funding opportunities and support for fourth-sector initiatives; support for citizens’ initiatives from youth and marginalised groups, e.g. Sámi youth, socially marginalised youth, mobile-based voting on services or initiatives for targeted groups, targeted crowdsourcing of ideas, and targeted co‑planning and co‑creation of events and initiatives are all areas that could be further developed (see Box 6.6 on engaging youth). At the national level, the co-creation of flagship government pledges and priorities could also be considered with members of the public, including content for the next government programme as part of a more future-oriented, strategic approach that focuses less on solutions to problems and more on societal goals or targets. Creative ways to channel citizens’ views into the process could be found as a means of enhancing the relationship between citizens (including underrepresented groups), political parties and the state, as well as a way to build trust.
In order to tackle the challenge of addressing complex or long-term societal challenges, mini-publics or juries could be institutionalised, moving them from what is largely the domain of academics to becoming a mainstreamed tool used by central and municipal governments alike to channel citizen opinions into decision making at national and local levels. This would have particular value because it would help to engage members of the general public Finns, instead of the current focus on stakeholders and self-selecting people. It would help to move away from the more traditional public engagement mechanisms – of public hearings, comments on draft documents and self-selective online consultations – towards a more representative way of gathering opinions. It could also be encouraging to institute reforms if conducted with a commitment to acting on the recommendations that emerge from these processes, in line with the OECD Good Practice Principles for Deliberative Processes for Public Decision Making (OECD, 2020[69]). Random sampling is crucial, as the aim is to include a “microcosm of the general public” (OECD, 2020[69]). The Good Practice Principles advise that a representative selection should be made from the random sample, noting that “everyone should have an equal opportunity to be selected as participants” (OECD, 2020[69]). Other principles – there are eleven in total - include linking the purpose of the panel or jury to a clearly defined societal problem (purpose); ensuring that all related information is made available to the public (transparency); and involving underrepresented groups (inclusion).
Box 6.6. Overcoming apathy among Finnish youth
The annual Youth Barometer carried out by the national State Youth Council – an expert body tasked with addressing issues of fundamental importance to young people - and the Finnish Youth Research Society showed that more young people than ever were interested in politics in 2018 (Pekkarinen, Elina; Myllyniemi, Sami (eds.), 2019[70]). This was attributed to high levels of interest in presidential elections that took place in 2012 and 2018, the global political situation, the global rise of populist groups, budget cuts in the education sector during the last government, the use of social media, concern about climate change, and activist movements such as Fridays for Future, which engage in climate protests.1 The barometer found that young people’s “active involvement in society” had increased and that a majority believed in traditional forms of civic participation, while trust in social institutions remained strong (Pekkarinen, Elina; Myllyniemi, Sami (eds.), 2019[70]). A full 49% “strongly agreed” or “somewhat agreed” with the statement that “most politicians are trustworthy” (Pekkarinen, Elina; Myllyniemi, Sami (eds.), 2019[70]).
The survey also illustrated a growing faith among youth in influencing decisions using non-parliamentary means, such as purchasing decisions, social media, or participation fora such as youth councils. In all cases, faith in influencing through these methods was higher than in 2013. 64% of people surveyed felt they could influence “a great deal” or “quite a lot” via participation in a youth council or organization, up from 62% in 2013 (Pekkarinen, Elina; Myllyniemi, Sami (eds.), 2019[70]). 66% felt they could influence “a great deal” or “quite a lot”” by voting, up from 62% in 2013.
Yet membership of political parties among youth remains low2 and voter turnout among younger Finns – a majority of whom feel no affinity for any of the traditional political parties (Kataja, 2017[71]) - is lower than among older groups. The highest voter turnout in Finland is between the ages of 55 and 74. As a result, political parties tend to invest in appealing to older groups in their manifestos and platforms. 44% of 15-24 year olds feel that political parties “do not promote matters important to me or people like me”, while 33% of people aged 65 and above feel the same (Pehkonen and Hyry, 2020[1]). Unsurprisingly, voting patterns among youth are clearly determined by education (Table 6.2) In the 2015 parliamentary elections, at the age of 25, 80% of those with higher university degrees voted, compared with just 20% of those with basic education.3
Table 6.2. Voter turnout in % according to age and education in 2019 parliamentary elections
Source: (Grönlund and Strandberg, 2019[72]).
This presents a twin challenge for policy makers in terms of how to engage youth in voting and decision-making and respond to their needs; and for youth, and particularly marginalised groups or persons, to make their voices heard to government actors. The Democracy Programme intends to tackle this issue by raising public authorities' awareness of children's and young people's participatory rights and seeking to strengthen equal participation of young people and good relations between population groups will be strengthened (Government of Finland, 2020[20]).
Evidence shows that youth groups favour non-traditional methods of participation such as those that are online, including citizen initiatives. Significantly, education does not play a significant role in determining involvement in citizen initiatives (Christensen et al., 2017[25]). Young people may also favour participation in single-issue opportunities for participation e.g. targeted online voting, surveys, quick impact projects (Kataja, 2017[71]). More targeted participation initiatives for youth in general, and in particular, sub-groups of marginalised youth e.g. Sámi youth, youth with migrant backgrounds, using tools and subjects that are appealing to them, could support the effort to engage them.
1. State Youth Council, PowerPoint presentation, 28 September 2020.
2. A national 2020 survey by SITRA shows that just 5% of 15-24 year olds were, or had ever been, a member of a political party (Pehkonen and Hyry, 2020[1]).
3. State Youth Council, PowerPoint presentation, 28 September 2020.
Source: (Pekkarinen, Elina; Myllyniemi, Sami (eds.), 2019[70]) (Kataja, 2017[71]) (Pehkonen and Hyry, 2020[1]) (Government of Finland, 2020[35]) (Christensen et al., 2017[25]) (Kataja, 2017[71]).
Adopting a holistic approach to engaging Finnish citizens as partners in decision making
Above all, it is important that initiatives to engage citizens are complemented by efforts to reduce social inequalities related to income, employment and education, with a focus on marginalised groups. One of the main challenges to the realisation of the fundamental freedoms and rights is intergenerational inequality and exclusion, according to the Chancellor of Justice (Office of the Chancellor of Justice, 2020[73]). The strengthening of targeted economic and social policies and services that seek to provide multi-sectoral support for disadvantaged groups and families, with a view to achieving better educational, financial and social attainment as well as life-coping skills, could help to counter this and even to engage people more broadly (Mattila, 2020[17]). As noted in Grönlund and Wass (2016[18]), given that political participation reflects the overall well-being of the citizen, “the most effective, but at the same time most challenging, opportunity to improve political equality is to reduce overall social inequality”.
Increasing people’s take up of and satisfaction with the many participation opportunities available to them remains a key challenge, with no easy entry points or solutions. As recommended earlier, targeted and sustained outreach efforts to increase citizen-state interactions between elections is the obvious starting point, including to boost low levels of awareness of the fundamental role that municipalities play in citizens’ everyday lives in terms of providing healthcare, services and education.47 The quality of interactions with the state and giving people a sense of being listened to are also fundamentally important.48 Training for municipal workers on effective, inclusive and targeted participation methods could help to develop their skills and reinvigorate existing methods to meet new or developing needs. Partnerships with suitably qualified third-sector actors could also be a sensible approach.
Overall, legal frameworks, oversight institutions and cultural norms appear to be resilient enough to protect Finland’s civic space beyond the current period. However, in the context of the recovery from the COVID‑19 pandemic, the sustained engagement of the public and a wide range of civil society groups, including those representing marginalised persons and working on human rights protections, will be key to ensuring an inclusive, fair and sustainable approach to policy making. The Chancellor of Justice and Deputy Chancellor of Justice have both drawn the government’s attention to the specific needs of the most vulnerable groups in society and it is key that government institutions continue to assess, highlight and respond to emerging needs. Monitoring of how the information gathered as part of the Finnish national dialogues is being used by different government agencies and communicating on this to the public may also help to prove the value of, and ensure support for, future initiatives of this type.
Finally, Finland’s focus on innovation and experimentation to engage people and reinforce support for civic freedoms, civic space and democracy more broadly is of utmost importance in the current climate. Its strong commitment to democracy and civic freedoms should never be taken for granted, given global and national trends including populism, disinformation, hate speech and the threat from extremist political groups and ideologies, coupled with the destabilising effect of economic uncertainty and volatility. The findings of this Scan should be shared widely across government and with Finnish political parties, particularly with a view to highlighting the identified challenges to Finnish civic space and democracy more broadly, adopting a long-term strategic approach to tackling them, and building consensus on the necessary reforms.
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[66] Velasco-Sánchez, E. (2021), Designing and managing an OGP multistakeholder forum, Open Government Partnership, https://www.opengovpartnership.org/wp-content/uploads/2016/09/Multistakeholder-Forum-Executive-Summary.pdf.
Notes
← 1. Email, YLE, received 12 January 2021.
← 2. Email, YLE, received 9 March 2021.
← 3. An analysis of the low voter turnout is beyond the scope of this Civic Space Scan.
← 4. Voting patterns were the following in the 2019 parliamentary elections: Finns living in Finland (72.1%), Finns living abroad (12.6%) and people entitled to vote (68.7%) (Ministry of the Interior, 2019[74]).
← 5. Voter turnout in Sweden, for example, was 86% in the most recent elections (OECD, 2020[75]). Voter turnout in Norway was 78% during recent elections (OECD, 2020[16]).
← 6. For background on participation practices in relation to the preparation of legislation as of 2010, see OECD (2010[30]).
← 7. Interview, Ministry of Justice, 30 September 2020.
← 8. Email, Office the Chancellor of Justice, received 6 October 2020.
← 9. Notably, the latest government programme commits to improving the competence of officials involved in law drafting and specifies that competence will be improved in the areas of fundamental and human rights issues (Government of Finland, 2019[12]). Furthermore, it says that impact assessments of laws will be strengthened by introducing a system for ex post regulatory impact analysis.
← 10. Interview, Ministry of Justice, 5 October 2020.
← 11. Interview, Amnesty International Finnish section, 28 October 2020.
← 12. Interview, SOSTE, 7 October 2020.
← 13. Interview, SOSTE, 7 October 2020; email, Central Union for Child Welfare, received 31 August 2020.
← 14. Interview, Ministry of the Environment, 25 September 2020.
← 15. Email, Ministry of the Environment, received 23 February 2021.
← 16. Interview, Ministry of Social Affairs and Health, 23 September 2020.
← 17. Interview, Ministry of Social Affairs and Health, 23 September 2020.
← 18. Interview, Ministry of Social Affairs and Health, 23 September 2020.
← 19. Interview, Ministry of Transport and Communications, 2 October 2020.
← 20. Interview, Timeout Foundation, 6 January 2021.
← 21. Interview, Timeout Foundation, 6 January 2021.
← 22. Email, Amnesty International Finnish section, received 14 January 2021; email, Finnish Human Rights Centre, received 18 January 2021; email SOSTE, received 19 January 2021; interview, Finnish League for Human Rights, 14 January 2021.
← 23. Email, Physicians for Social Responsibility – Finland, received 29 January 2021.
← 24. Interview, Finnish League for Human Rights, 14 January 2021.
← 25. Email, SOSTE, received 19 January 2021.
← 26. Interview, City of Tampere, 9 November 2020.
← 27. Interview, City of Tampere, 9 November 2020.
← 28. Interview, City of Tampere, 9 November 2020.
← 29. Interview, City of Tampere, 27 November 2020.
← 30. Interview, City of Tampere, 27 November 2020.
← 31. Interview, City of Tampere, 27 November 2020.
← 32. Email, Åbo Akademi University, received 2 November 2020.
← 33. Email, Åbo Akademi University, received 2 November 2020.
← 34. Email, Åbo Akademi University, received 2 November 2020.
← 35. Email, Åbo Akademi University, received 2 November 2020.
← 36. The draft OECD Best Practice Principles for Stakeholder Engagement in Regulatory Policy state that engagement with stakeholders should start as early as possible in the process. When developing new regulations, stakeholders' input should be used when defining the problem and the goals for the new regulation, particularly in cases where there is a lack of data and the regulator has not decided to move forward with a proposal. In fact, even before the work starts on preparing a new law or regulation, stakeholders might be consulted, for example, through green and white papers.
← 37. Interview, SOSTE, 7 October 2020.
← 38. Interview, Ministry of Transport and Communications, 2 October 2020.
← 39. Email, SOSTE, received 31 August 2020.
← 40. Interview, Finnish League for Human Rights, 6 October 2020.
← 41. Interview, National Audit Office, 21 September 2020.
← 42. Interview, Finnish League for Human Rights, 6 October 2020.
← 43. Interview, Ministry of Justice, 5 October 2020.
← 44. Interview, Finnish League for Human Rights, 6 October 2020.
← 45. Speech by former President of the Supreme Administrative Court, Pekka Vihervuori, 27 January 2017 (unofficial translation from Finnish).
← 46. Email, SOSTE, received 31 August 2020.
← 47. Interview, Ministry of Finance, 23 September 2020.
← 48. Interview, Ministry of Finance, 23 September 2020.