Processing personal information for income-based preschool fee discounts
To apply for an income-based discount on the preschool day care fee, parents must consent to the processing of their personal information to verify their income meets the thresholds in Reykjavík City's fee schedule.
Preschool fee discount
Under Reykjavík City’s preschool fee schedule and the Rules on Preschool Services, parents can receive a discount on preschool fees by submitting an application through Vala, the online application portal, if their income falls within the limits set by the City’s Department of Education and Youth in its fee schedule. The discount does not apply to meal fees.
The City must receive your application before the 20th of the month for the discount to take effect on the first day of the following month. For more details about the terms of the discount, see the fee schedule and the Rules on Preschool Services.
Terms and conditions
- Under the Rules on Preschool Services, if all requirements are met, the parent who shares the preschool child’s legal residence and legal residence affiliation in Registers Iceland records receives the discount. A single parent must also be registered as single with Registers Iceland. For sibling discounts in joint physical custody arrangements, the fees are reduced for the parent who makes the payment.
- To qualify for an income-based discount, your total annual income reported on your tax return must fall within the limits in the fee schedule of Reykjavík City’s Department of Education and Youth. The City uses the total annual income shown on the most recent tax return approved by the Director of Internal Revenue.
- Each year, the discount expires on Sept. 1 unless you renew it before Aug. 20.
- The income limits for single parents apply only if the parent is registered as single with Registers Iceland. The Department of Education and Youth may ask parents to provide a statement confirming that they are single. If parents divorce or stop living together as a couple, the discount takes effect on the day the City receives the application, provided Registers Iceland records show the change in marital status. The income limits for single parents do not apply if the parents share the same legal residence.
- The Department of Education and Youth reserves the right to request documents or confirmation to verify that the requirements for the discount are met. Examples include a copy of a tax return approved by the Director of Internal Revenue, a copy of a fee notice, or comparable documents that verify income.
- If the Department of Education and Youth does not receive the requested documents or confirmation by the deadline, it may deny the discount or end an existing discount until it receives sufficient documentation.
- The discount ends without notice if the parents do not meet the eligibility requirements. Under the general rules of the law of obligations, the City may recover any discount granted based on incorrect or misleading information and will require those concerned to pay the difference.
- This policy also applies to parents whose children attend a private preschool with a service agreement with Reykjavík City, although the specific discount is determined by the terms of that agreement.
Data controller
Reykjavík City is the data controller, and Infomentor ehf is the data processor. Reykjavík City has a processing agreement with Infomentor ehf.
What is the purpose for processing and its basis?
The purpose of this data collection is to provide income-based discounts to eligible parents. The processing of personal data from applications for income-based discounts is necessary for Reykjavík City to determine whether applicants qualify under the Rules on Preschool Services and the Department of Education and Youth’s fee schedule. This processing is part of the municipality’s work to carry out its statutory duties. The legal basis for this processing is Article 9, paragraph 1, item 5 of Act No. 90/2018 on Data Protection and the Processing of Personal Data.
If you do not provide the requested information, Reykjavík City may be unable to process your application for an income-based discount; however, this will not affect the child's preschool service.
Data storage
The City deletes your personal data related to the income limits. As required by law, the City keeps records of any discount granted and the preschool fees in its financial systems for as long as those records serve a practical purpose.
If the Department of Education and Youth requests documents, such as a tax return or fee notice, to verify that you meet the requirements for the discount, it deletes them once the review is complete. The City records the outcome of the review.
What personal data is processed?
When you apply for an income-based discount through Vala, the system processes the information you provide along with other required and specified data.
Vala connects automatically to Registers Iceland to gather basic personal information on the registration page, such as the service user's name, ID number, and legal residence. Vala checks the guardian's marital status (single parent or cohabiting) with Registers Iceland and displays the relevant application options. The application displays the names of the child and the logged-in parent.
The service user can start an application on the website to apply for an income-based preschool fee discount.
Vala processes the application automatically and records the discount percentage on the child's profile. Reykjavík City's accounting system handles invoicing based on the available data.
The City processes the names, ID numbers, home addresses, phone numbers, and email addresses of parents whose child attends preschool. It also processes information about preschool-age siblings, monthly billing, documents submitted as attachments, marital status, whether income falls within the limits, and documents that verify income. Records of outstanding payments are kept in the access-controlled system. We also process technical information, such as the IP address, the device used to sign in, and actions taken in the system.
The categories of data subjects are:
- Parents and their children.
- Staff of the data controller and private preschools with access to the application system.
Where does the information come from?
Basic data is sourced from Registers Iceland, Vala, and from parents during the application process.
How long is the personal data kept?
The City deletes your personal data related to the income limits. As required by law, the City keeps records of any discount granted and the preschool fees in its financial systems for as long as those records serve a practical purpose. If the Department of Education and Youth requests documents, such as a tax return or fee notice, to verify that you meet the requirements for the discount, it deletes them once the review is complete. In accordance with the Public Archives Act (Act No. 77/2014), the City keeps a record of the outcome of the review. After the specified retention period, all processed data must be transferred to the National Archives of Iceland for preservation, per Act No. 77/2014 on Public Archives.
How do we ensure the security of personal data?
Reykjavík City uses appropriate organizational and technical measures to protect personal data, including access controls and encryption. All City staff involved in processing an applicant's personal data are bound by confidentiality.
Sharing personal data with third parties
The City of Reykjavík will not share any other personal data belonging to you with third parties unless the City is required to do so on the basis of law, governmental orders, or a court order. Furthermore, the City will not share your personal data outside the European Economic Area without express authorization and without informing you accordingly.
Automatic decision-making
Applications for income-based preschool fee discounts are processed using automated decision-making, meaning they are handled automatically based on parental consent and without human intervention.
When a parent applies for an income-based discount, the system automatically determines whether to grant it based on the income requirements in the fee schedule. If their income falls within the thresholds, the system determines the discount based on the applicable discount category. If their income exceeds the thresholds, no discount is granted.
If the system makes an automated decision on your application, you have the right to have a Reykjavík City employee review the basis for the decision and its outcome. You also have the right to present your views, receive an explanation, and contest the decision. You also have the right to object to the automated processing of your application, and parents can always request a manual decision instead. You can send inquiries about this to sfs@reykjavik.is.
Your rights
You may have the right to access the personal data that the City of Reykjavík processes in connection with your application. You may also have the right to object to the processing, have the information corrected, request that it be deleted, have the processing limited, and/or have the information delivered to you or a third party in machine-readable format. More information about these rights can be found in Reykjavík City's privacy policy.
Complaints about processing
Please note that if you're dissatisfied with Reykjavík City's handling of your personal information, you can always contact the City's Data Protection Officer (personuverndarfulltrui@reykjavik.is) or file a complaint with the Icelandic Data Protection Authority (postur@personuvernd.is).