WORKING DOCUMENT Optimizing Finnish Immigration Process for highly qualified experts

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WORKING DOCUMENT Optimizing Finnish Immigratin Prcess fr highly qualified experts V. 0.9 21.5.2018 Jari-Pekka Kaleva (Negames) Anna Mikkla V. 0.95. 6.9.2018 Veera Alahuhta (Negames)

Intrductin This is a wrking dcument that maps the current status f immigratin prcess f specialist relcating t Finland. Table f Cntents: Intrductin... 2 Table f Cntents:... 2 Plicy recmmendatins... 3 Summary: Frm a freign super talent t a leading Finnish expert in ne mnth... 5 What des this mean in practice? An example f immigratin prcess:... 6 Optimizing Finnish Immigratin Prcess fr Highly Qualified Specialist... 7 Annex 1: Abbreviatins... 14 2

Plicy recmmendatins 2018-2019: Taking the easy steps High level plicy decisins - Frm inter-gvernmental sils t c-peratin: All ministries and gvernmental agencies shuld c-perate in building a smth decisin making chain frm step 2 t the end f step 3 in this dcument. This might require a crss gvernmental wrking grup. - Buck-passing has t end: All actrs in the decisin-making chain shuld trust n the identificatin dne by the embassy and that shuld be the nly step where a face t face meeting with public authrities is needed. An emplyee immigrating t Finland has t have clear, cherent and crrect infrmatin n all steps in the decisin-making chain frm ne website. egvernment: - Vide appintments: When physical presence is nt needed, it shuld be pssible t have vide appintments with public authrities - Receipts: Cmpanies need receipts t fulfil Finnish accunting requirements. Public authrities have t prvide receipts fr all the payments n their services. - Strict nce-nly principle fr the prcess: Ulkmaalaisrekisterilaki has t be built futureprf s that it allws full data transfers between all parties in the decisin-making chain. All data shuld be requested as early as pssible and nly nce during the prcess. 2019-: 100 millin eurs fr getting the best talent in the wrld t mve t Finland High level plicy decisins: - Crss gvernmental plicy gals: Clear target dates shuld be set fr the whle prcess (e.g. Step 2 in this dcument), instead f n nly sme parts f it at a time. The whle prcess frm step 2 t the end f step 3 in this dcument shuld nt take lnger than 1 mnth. This means that each step f the prcess needs be streamlined and made mre accessible in English. - English: English shuld be ne f the fficial languages used in the immigratin making prcess. - N welcme-t-finland-tax: Immigratin csts paid by the emplyer shuld nt be cnsidered taxable persnal incme. Immigratin-related expenses paid by the emplyee shuld be deductible frm persnal incme tax (als Finnish ID card). Sufficient resurces fr: - Marketing and branding: Talent Finland has t have sufficient resurces fr successful natin branding in c-peratin with cities. The capital regin has t marketed under single unified brand. - Gd service design: Migri s InLand team shuld be respnsible fr the service design f the whle immigratin prcess frm an embassy t Ver. - Smth and reliable service chain: All actrs in the decisin-making chain shuld have sufficient resurces fr prviding clear infrmatin n the immigratin prcess in English and fr quick and reliable decisin-making als during bth hliday seasns and rush times (when new students arrive t Finland). - One stp shps: All services fr emplyees immigrating t Finland shuld be available frm Talent Finland ne stp shps. - Synergies thrugh c-peratin: In c-peratin with ther EU/Nrdic cuntries, embassy netwrk accepting residence permit applicatins have t be widened. - Integratin: Sufficient supprt fr the integratin f spuses t Finnish jb markets has t be secured, as therwise the recruited specialists mve away frm Finland. - Access t educatin: All children mving t Finland with highly skilled specialist shuld have autmatic and immediate access t pre-schl, basic and secndary educatin in ther languages than Finnish r Swedish. Satisfactry is nt gd enugh - Immigratin bureaucracy is mre than just paper wrk, it is als abut engaging highly qualified experts t Finland: All highly qualified experts shuld receive an fficial Welcme Bx while picking up their residence permit card. egvernment - Single tracking tl fr the whle prcess: Tracking tls allwing immigrating emplyees t fllw the status f their whle immigratin prcess thrugh steps 2 and 3 in this dcument. This wuld enable gvernment t fllw actual decisinmaking times instead f just small parts f them. - Universal Digital Embassy: Finnish embassies abrad shuld build their immigratin services arund a digital platfrm, s that n excessive traveling during the immigratin prcess shuld be required frm the applicant befre actually mving t Finland. Flying frm state f residence t an embassy csts huge amunt f emissins, and in many cases slws the prcess dwn significantly. - A single service t unite them all: All the infrmatin frm fr the whle immigratin prcess and clear checklist fr each step in it frm an embassy t tax registratin shuld be centralized n a single website. Bth the emplyer and applicant shuld have access t mdify the applicatins and track their status in the administrative prcess. The infrmatin submitted thrugh the site shuld be stred n user accunts s that all infrmatin wuld be ready fr reapplying the residence permit 3

when needed. The ntificatins frm the prgress and status f the immigratin prcess shuld be sent t bth the emplyer and emplyee. - One applicatin: A single applicatin prcess fr the whle family. - Preliminary decisins: The system shuld allw making preliminary decisins that are autmatically carried ut when all required preceding decisin-making steps have been carried ut. - esignature: Electrnic signatures shuld be accepted frm trusted cuntries. Finnish gvernment has t take a lead n building a glbal standard fr esignatures. - Enabling algrithmic decisin making: Humans shuld make decisins n unclear cases. All clear cases shuld be apprved by decisin making algrithms. This means that the cmpetent authrities liability (virkavastuu) shuld be widened frm an individual decisin t autmated decisin making system. 4

Summary: Frm a freign super talent t a leading Finnish expert in ne mnth Current times and target times f different steps in immigratin prcess (days) 1. Finding a highly qualified persn, wh is ready t mve t Finland. STEP 1: Making Finland an attractive place t wrk 1. An emplyee agrees t mve t Finland 2. Registratin at Enter Finland prtal STEP 2: Overcming the bureaucratic bstacles in the residence permit prcess 3. Meeting at the embassy 4. A cnfirmatin frm the embassy 5. A decisin frm Migri 6. A printing cmpany prints and sends the card 7. Embassy checks the card and sends it t the emplyee 8, An emplyee flies t Finland Smetimes mre than a mnth 1. Registratin fr a place f residence (ktikunta) at magistrate 2. Natinal identity card frm plice STEP 3: Overcming the bureaucratic bstacles in the registratin prcess in Finland 3. Getting access t a strng identificatin system frm a bank 4. Registering t KELA fr health insurance and health care 5. Registering t VERO fr a tax card Smetimes mre than a mnth 1. Finding a jb fr spuse 2. Finding a schl fr kids STEP 4: Integrating in Finland Can take years Can take a year Target time Current time (max) 5

What des this mean in practice? An example f immigratin prcess: Date: Actin taken 7.11.2017 A game develper studi started t lk fr a new highly skilled specialist 26.1.2018 After abut tw mnths, the game develper studi fund a new emplyee frm India that was ready t mve t Finland 30.1.2018 It tk tw days fr the emplyee t register at Enter Finland Prtal 27.3.2018 The persn was frced t wait tw mnths befre there was free times lt fr a meeting at the Embassy in New Delhi. 29.3.2018 An apprval frm the Embassy. 22.4.2018 A residence permit arrives t Embassy and the persn can fly t Finland. 6

Optimizing Finnish Immigratin Prcess fr Highly Qualified Specialist Targeted times f different steps in immigratin prcess (days) Target time Current time STEP 1: Making Finland an attractive place t wrk 1. RECRUITEMENT Finding a highly qualified persn, wh is ready t mve t Finland Can take frm mnths t years What: Marketing Finland as an attractive place t wrk Slutins: - Glbal Presence (UM, TEM, Cities/Regins): Cntinuus glbal presence f Finland in glbal media and key industry events - Marketing material (UM, Cities/Regins): Easily available, cnstantly updated and high-quality marketing material n Finland and its game dev hubs as a place t live and wrk. Especially testimnials are needed. - A tlbx (UM, TEM): Tlbx helping Finnish cmpanies t tackle immigratin prcess. - Exceptin management (TEM): Business Finland shuld supprt cmpanies in building up exceptin management strategies - Single brand fr capital regin (Cities): Imprving glbal attractiveness f the capital regin under a single unified brand STEP 2: Overcming the bureaucratic bstacles in the residence permit prcess (max 30 days) 1. A CONTRACT A new emplyee agrees t mve t Finland Nw: 2-5 days Target: 0 days The reasn fr delay: Psting physical cpies f signed dcuments frm emplyee t an embassy and t an emplyer. Slutin: - esignature (UM, VM): The embassy shuld always accept electrnic signatures frm trusteed cuntries. On the lng run, a glbal system fr electrnic signatures is needed. - Call-back service (UM): If prblems shuld ccur, the embassy shuld call t emplyer fr clarificatin 7

2. A REGISTRATION at Enter Finland Prtal Nw: few days Target: 0 days The reasn fr delay: The emplyee is struggling with misleading infrmatin n Enter Finland Prtal while submitting the electrnic applicatin Slutin: - Check-lists (SM/Migri, UM): Migri and UM shuld prvide clear checklists and easy t understand animated vides n hw t apply a residence permit in different cases. - Lw-threshld supprt (Migri): Migri shuld run a scial media grup (e,g. n Facebk r LinkedIn) where they culd infrm HR specialists n changes in the immigratin prcess and reply t questins. - Crrect infrmatin (SM/Migri, UM): Remving misleading infrmatin frm the website (e.g. can ne first cme t Finland with an existing Schengen Visa and apply a residence permit frm Finland, is a degree frm higher educatin required) and making the access t right frms easier (e.g. the frm t use with spuses wh are nt in Finland) e.g. by intrducing a well-wrking search functin in English. The website intrducing the requirements fr highly qualified experts shuld have sme examples frm games industry (e.g. game artists and cders). Migri has t give clear guidelines fr the frmal requirements, s that there are n surprises t the applicant. - Functinal payment services (SM/Migri): Cmpanies shuld be able t pay bth the residence permits f their emplyees and their families n the EnterFinland site. There has t be an easy way t get a receipt frm all payments dne by cmpanies. - Tracking system (SM/Migri): A tracking system needs t be build, s that the emplyee can track the status f his r her applicatin thrugh the whle prcess frm the embassy t Migri and back. - Single service t unite them all (SM/Migri, UM/embassies, TEM, VM/Ver/Maistraatti): All the infrmatin frm the whle immigratin prcess frm an embassy t tax registratin shuld be centralized n a single website. Bth the emplyer and applicant shuld have an access t mdify the applicatin. The infrmatin submitted n thrugh the site shuld be stred n user accunts s that all infrmatin wuld be ready fr reapplying the residence permit when needed. The ntificatins frm the prgress and status f the immigratin prcess shuld be sent t bth the emplyer and emplyee. - One applicatin (SM/Migri): If the specialist mving t Finland has family members, they can apply fr a residence permit at the same time. The gal f the Finnish Immigratin Service is t make a decisin n whle family's applicatins simultaneusly, but this is nt always pssible. Cnsequently, instead f submitting different applicatins, the whle family shuld be able t apply residence permits under a single applicatin. 3. AN APPOINTMENT at an embassy Nw: Frm few days t weeks Target: an appintment in 1 week, The reasn fr delay: Delays in getting a timeslt frm the embassy fr identificatin and submitting the applicatin (fingerprints) and pssibly flying t get t the embassy. Slutin:. - Universal Digital Finnish Embassy (UM): Universal Digital Embassy shuld be established, s that the applicants wuldn t have t travel t a physical embassy. Excessive flying causes harmful emissins and, in many cases, slws the prcess dwn significantly. Vide appintments shuld be made available when pssible. 8

4. A CONFIRMATION frm the embassy Nw: Frm few days t weeks Target: an apprval in 1 day The reasn fr delay: Delays in getting a cnfirmatin frm the embassy t Migri fr starting the applicatin review prcess Slutins: - Sufficient Human Resurces (UM): The embassy has t have enugh human resurces cnfirm the applicatin within 1 day frm the appintment - Accessibility (UM): The electrnic systems fr handling the residence permit applicatins shuld be accessible in a lcal language r at least in English s that embassies culd hire and train lcal staff fr prcessing the applicatins - Gd public prcurement (UM): Pssible use f utsurced services like VFS fr prcessing the applicatins shuld nt create an extra lag t the prcess - Synergies thrugh cperatin (UM): On the lng run, c-peratin with ther EU/Nrdic Embassies n securing that applicatin can be given in an embassy clsest t the applicant. A Eurpean standard fr identifying a persn is needed fr this. 5. A DECISION frm Migri Nw: frm few days t mnths Target: 3 days The reasn fr delay: Migri is under-resurced t prcess the applicatins n time, especially under peak mnths and hliday seasns Slutin: - Sufficient resurces (SM/Migri): Migri has t have sufficient human resurces t prcess the applicatins in 3 days, even during the busy seasns 6. THE RESIDENCE PERMIT CARD Printing and sending the residence permit card Nw: Abut 2 weeks Target:1 week The reasn fr delay: A cmpany subcntracted fr printing the residence permit card prints it and sends it t the embassy. Printing and sending the printed card takes t much time. Slutin: - Sufficient resurces (SM/Migri): Mre resurces fr the printing cmpany fr printing and sending the cards 9

7. A CHECK The embassy checks the card and sends it t the emplyee Nw: Abut a week Target: 3 days The reasn fr delay: Delays in checking the card and sending the card t applicant r asking the applicant t cllect the card frm embassy Slutins: - Functinal payment services (UM): The applicant shuld be allwed t pay the psting csts already when the residence permit applicatin is submitted. On the lng run, there shuld be a way fr the cmpany t pay these csts directly. - Sufficient resurces (UM): The embassy has t have enugh human resurces t prcess the applicatin in ne day - Functinal delivery: (UM) In all cuntries, where it is pssible, the embassy shuld prvide an pprtunity t send the residence permit card autmatically t the emplyee frm the embassy by using a trusted curier. The embassy has t clearly infrm all applicants abut this pssibility. (UM) The embassy has t have an access t a system that autmatically sends a ntificatin t the emplyee applying the residence permit, when the card arrives t the embassy and when they can cme t cllect it, r it has been sent frward frm the embassy t the emplyee. (UM, SM/Migri) In the shrt run, handling and prcessing the residence permit applicatins shuld be utsurced t cmpanies like VFS as far as pssible. In the lng run, Ulkmaalaislaki has t be amended in a way that residence permit cards can be sent directly t the emplyee frm the manufacturer in cuntries where pst system allws this. (UM/SM) There shuld be an ptin fr applicants t ask their residence permit cards t be sent t and checked at Helsinki-Vantaa Airprt upn their arrival t Finland. - Welcme bx (UM, SM/Migri): In additin t fficial immigratin dcuments everyne mving t Finland shuld receive an fficial Welcme Bx infrming the applicant abut the next steps f immigratin prcess including a reminder f their respnsibility t ntify Migri f all status changes immediately. 8. A RELOCATION The emplyee mves t Finland Nw: Abut a week The reasn fr delay: Bking the tickets and flying t Finland 10

STEP 3: Overcming the bureaucratic bstacles in the registratin prcess in Finland 1. A PLACE OF RESIDENCE Registratin fr a place f residence (ktikunta) at magistrate Nw: frm ne t tw days Target: 0 days The reasn fr delay: The emplyee must g physically t lcal register ffice (magistrate) in rder t register her r himself fr an fficial place f residence (ktikunta). Finnish pst service wrks slwer and slwer, which causes delays n sending and receiving the applicatins. Slutins: - Accessible services (VM): The lcal register ffice (magistrate) shuld accept English as transactin language (SOLVED) - Ask nly nce (VM, UM): Mving all data autmatically frm the residence permit data base t the Ppulatin infrmatin system, including infrmatin n children and spuse. Fr this reasn Ulkmaalaisrekisterilaki has t be amended in a way that autmatic data transfers are pssible and each actr in the prcess has t be trained fr cllecting the infrmatin s reliably that It des nt need t be duble checked later in the prcess. - Smart autmated decisin-making (VM): The registratin shuld be dne electrnically and autmatically n the mment the residence permit is granted. In the shrt run, magistrate has t have sufficient number f staff fr prcessing the applicatins quickly under all circumstances. On the lng run, purely administrative decisins shuld be made by algrithms cntrlled by cmpetent public fficial with clear liability n the decisins. - Accessible services (VM): A fully electrnic service is needed als fr thse wh d nt have access t strng electrnic identificatin system (e.g. the decisin wuld be accessible nline with a passwrd given t the emplyee when he r she registers in magistrate) 2. A NATIONAL IDENTITY CARD frm plice Nw: a week Target: 0 days The reasn fr delay: In rder t get a natinal identity card, the emplyee must be reidentified by plice Slutins: - Functinal delivery: (SM/Migri)The infrmatin fr the natinal identity card shuld be autmatically transferred frm the residence permit applicatin (SM/Migri) The persn shuld be allwed t prerder the natinal identity card already when she r he submits the residence permit applicatin - Ask nly nce (UM, SM/Migri): Fr persns cming frm trusted cuntries, the identificatin dne at the embassy shuld be enugh. - 3. AN ACCESS TO STRONG IDENTIFICATION SYSTEM frm a bank Nw: 1-2 days Target: 1-2 days The reasn fr delay: A persn needs a natinal identity card in rder t get nline banking accunts frm a bank, which are needed in t get access t strng identificatin system allwing him r her t access public services nline. Slutins: 11

- Natinal identity card shuld nt be required fr granting an access t strng nline identificatin system, a passprt and residence permit shuld be enugh 4. HEALTH INSURANCE AND PUBLIC HEALTH CARE frm KELA Nw: Abut 1 mnth Target: 0 days The reasn fr delay: Delays in registratin t KELA fr health insurance and public health care Slutins: - Streamlined applicatin prcess (SM/Migri): The emplyee shuld be allwed t apply fr the health insurance, while filling the residence permit applicatin. - Accessible services (STM): Key infrmatin abut the health insurance decisin shuld be available in English - Ask nly nce (SM/Migri): Ulkmaalaisrekisterilaki s 10 shuld be implemented in a way that allws full data transfer t Kela. Data transfers frm Ulkmaalaisrekisteri t KELA shuld be technically pssible. - Sufficient resurces ( STM/KELA): KELA has t have sufficient resurces fr prcessing the applicatins. KELA card shuld nt take 6 mnths t arrive. 5. A TAX CARD Registering t tax authrity fr a tax card Nw: 0 days t weeks Target: 0 days The reasn fr delay: An emplyee must register t VERO fr taxatin. Hwever, fr freign specialists/key emplyees nly the capital regin can ffer tax administratin services that are fast, as there the tax administratin is familiar with internatinal situatins. Outside the capital regin a mre cmplex tax card applicatin can take several weeks as the tax ffice needs t check legislatin/practice befre making a decisin. Slutins: - Streamlined applicatin prcess (SM/Migri): One shuld be able t apply a tax card already while applying the residence permit - Ask nly nce (VM): The infrmatin fr a tax card shuld be autmatically transferred frm the residence permit applicatin STEP 4: Integrating in Finland 1. A NEW HOME Starting a new life in Finland Slutins: - Accessible services (Natinal gvernment, cities): All key public services shuld be available in English - Tlbx (Cities): A tl-bx fr finding a flat, hbbies etc. - N welcme t Finland tax (VM): Immigratin csts paid by the emplyer shuld nt be cnsidered as taxable persnal incme welcme-t-finland tax 12

2. A SPOUSE Finding a jb fr a spuse Nw: 1 mnth t years Target: half a year The reasn fr delay: If the emplyee s spuse is unable t find a jb, the cuple / family is likely t leave Finland Slutins: - Sufficient resurces (TEM): Well-resurced Talent Finland Hubs in all key game dev hubs in Finland - Targeted services (TEM): - Better services (TEM): Academically educated freign wrkfrce in the Finnish jb market, riginally arriving t Finland as spuses f a persn emplyed in Finland, shuld be a special fcus area f public services Public emplyment services shuld have at least ne service pint where specifically trained persnnel fr highly educated freigners are available Integratin plans shuld be mre thught ver, lnger, and have mre detail. The rules f the Finnish labur market shuld be better explained t all clients. - Accessible services (TEM): Waiting time frm public emplyment service evaluatin t actual integratin plan steps, such as language curse placement, shuld be cut frm current several mnths t maximum 1 mnth. Public emplyment services shuld ffer nline services in English. - Single pint f cntact (SM, TEM, Cities): Cities and the natinal gvernment shuld build up well-resurced Internatinal Huses, where all immigratin services are easily accessible. 3. CHILDREN Finding a schl fr kids Nw: frm 1 mnth t 1 year Target: 1 mnth The reasn fr delay: Fr example, in Helsinki there are nt enugh places fr children in public schls prviding educatin in English. In the wrst case, a child des nt pass the entrance examinatin t a schl (e.g. SYK in Helsinki) and she r he frced t use a year t study Finnish t be able t enrll t a Finnish schl. This is particularly challenging fr children in the lder end f cmpulsry educatin, as it means they need t take a gap year frm all subjects while they learn Finnish. Slutin: - Accessible educatin (Cities): Cities must pen schls prviding pre-schl, primary and secndary educatin in ther languages than Finnish r Swedish. 13

Annex 1: Abbreviatins EU KELA Maistraatti Migri SM TEM UM Ver VM Eurpan unini, the Eurpean Unin Scial Insurance Institutin in Finland (public entity) Magistrate Finnish Immigratin Services Sisäministeriö, Ministry f the Interir Työ- ja elinkeinministeriö, Ministry f Labur and Livelihd Ulkministeriö, Ministry f Freign Affairs Verhallint, Finnish Tax Authrities Valtivarainministeriö, Ministry f Finances 14