Self-Monitoring Plan
updated 29.8.2025, version 1.2
Self-monitoring Plan:
Table of Contents
1. Service Provider, Service Unit and Operations
1.1. Service Provider's Basic Information
1.2. Service Unit's Basic Information
1.3. Services, Mission Statement and Operating Principles
2. Client Safety
2.1. Qualitative Prerequisites for Services
2.2. Responsibility for Service Quality
2.3. Client Status and Rights
2.4. Personnel
2.5. Premises
2.6. Use of Information Systems and Technology
2.7. Processing of Client Data and Data Protection
2.8. Consideration of Regular and Other Feedback
3. Self-monitoring Risk Management
3.1. Risk Management Responsibilities, Identification and Assessment
3.2. Means for Addressing Problems and Deficiencies in Operations
3.3. Monitoring, Reporting, and Ensuring Competence in Risk Management
3.4. Purchased Services and Subcontracting
3.5. Preparedness and Business Continuity Management
4. Publication, Implementation, Monitoring and Updating of the Self-monitoring Plan
4.1. Implementation
4.2. Publication, Monitoring of Implementation and Updating
1. Service Provider, Service Unit and Operations
1.1. Service Provider's Basic Information
Service Provider Name: Terapiapalvelut Viisas susi Oy
Business ID: 3515705-9
Postal Address: Hämeenkatu 29 A 1
Postal Code: 33200 Tampere
Phone Number: 045 783 46640
Email: terapiapalvelut@viisassusi.fi
Service Provider's Person in Charge: Oskari Ventilä
1.2. Service Unit's Basic Information
Service Unit Name: Flexio Oy's therapy center
Field: Health services
Postal Address: Hämeenkatu 29 A 1
Postal Code: 33200 Tampere
1.3. Services, Mission Statement and Operating Principles
Terapiapalvelut Viisas susi Oy provides effective, high-quality and comprehensive psychotherapy for adults and adolescents. The main target group is Kela's (Social Insurance Institution of Finland) rehabilitation psychotherapy clients. Self-paid therapy is possible as well. The company can provide various training and lecturing services. In-person appointments are held in the Flexio Oy's therapy center premises in Tampere city center. It's possible to conduct therapy appointments and lectures remotely, regardless of location. The company's operational plan is two-phased:
A) Starting 14.4.2025, the service provider will work as a practitioner for Flexio Oy, relying on Flexio's organization, premises, information systems, equipment and skilled staff.
B) Starting 1.9.2025, the service provider will transition to operating as an independent therapy company, working in Flexio Oy's therapy center premises under a rental agreement.
This distinction continues throughout the self-monitoring plan and is marked with corresponding letters (A = operating as a practitioner, B = operating as an independent therapy company).
2. Client and Patient Safety
2.1. Qualitative Prerequisites for Services
A+B) All services are provided by a licensed healthcare professional (Oskari Ventilä). Valid license and qualification information can be checked from the JulkiTerhikki service. The service provider is committed to continuously maintaining and developing their professional skills, participating in regular supervision and familiarizing themselves with current regulations, orders and good practices concerning their professional activities.
A) When operating as a practitioner for Flexio Oy, the service provider is committed to Flexio's general operating principles and quality standards. More detailed information about Flexio's operations and self-monitoring can be found in Flexio's self-monitoring plan.
2.2. Responsibility for Service Quality
A+B) The service provider is committed to following generally accepted therapeutic principles and professional ethical guidelines in their work:
Treatment is based on the client's individual needs and goals, agreed upon in mutual understanding with the client.
Treatment is based on therapeutic methods supported by clinical experience and scientific evidence.
Doing good, avoiding harm, respecting client autonomy, justice and impartiality, confidentiality and professional secrecy, professional competence and continuous development, openness and honesty, responsibility and cooperation.
A) The service provider is committed to following the general terms, operating and service practices, guidelines and quality systems applicable at Flexio Oy's therapy center.
2.3. Client Status and Rights
A+B) The service provider considers the legislation concerning client rights in their operations and strives to ensure the high quality and ethical implementation of their services. If a client is dissatisfied with the care or treatment they have received and the matter cannot be resolved directly with the service provider, the client has the right to contact the patient advocate for the Pirkanmaa welfare area to move the matter forward. The service provider is committed to handling any possible complaint, grievance, suspicion of harm or claim for compensation appropriately and as required by law. The service provider has valid patient insurance and the company's liability insurance.
2.4. Personnel
A+B) The service provider is a licensed psychotherapist and specialist in psychiatry, Oskari Ventilä.
2.5. Premises
A+B) The service provider operates at Flexio Oy's therapy center, where the premises meet requirements for client safety, privacy and healthcare services like psychotherapy. As a landlord, Flexio is responsible for access control, as well as burglary and fire protection for the premises. The service provider acts according to the instructions received from Flexio regarding the careful handling of access credentials and the use of the therapy center's premises. The service provider has familiarized themselves with the therapy center's rescue plan, exit safety report, initial extinguishing equipment, and participates in fire and rescue drills organized in the premises.
2.6. Use of Information Systems and Technology
A) Flexio's client information system is the SaaS-based (Software as a Service) Diarium, maintained by Nordhealth Oy (2162673-1). Zoom software is used for possible remote appointments. Client records are made in the electronic system according to Flexio's jointly agreed practices.
B) The service provider uses the SaaS-based (Software as a Service) Brightlife Flow client information system, which is maintained by Tampere-based Brightlife Oy (3252835-2). It is a Valvira A1 licensed healthcare information system that fulfills requirements for data security, protection, functionality and compatibility. Brightlife Flow's remote appointment function, which is approved for healthcare use, is used for remote appointments. Patient records are written electronically to Kanta via the Atostek ERA interface used by Brightlife Flow. The records are made in a manner required by law, but considering the nature of psychotherapy, always sensitively and respecting the client's privacy.
2.7. Processing of Client Data and Data Protection
A+B) The service provider prepares patient records in accordance with the Act on Health Care Professionals and the Act on Patient Data, noting the necessary information to ensure the organization, planning, implementation and monitoring of care.
A) The records are made and stored in the electronic system, Diarium. Flexio Oy acts as the data controller for client and personal data, being responsible for its obligations related to data processing, protection and storage in accordance with the EU's General Data Protection Regulation (GDPR) and other key legislation. Flexio requires the service provider to commit to its data protection practices. These are familiarized when Flexio introduces the service provider to its electronic system. In Flexio's premises, there are more detailed instructions for personnel regarding the secrecy, processing and disclosure of client data. The client has the opportunity to receive Flexio's log data, which shows who has processed their data.
B) The records are made and stored in the electronic system, Brightlife Flow. The service provider acts as the data controller for client and personal data, being responsible for its obligations related to data processing, protection, and storage in accordance with the EU's General Data Protection Regulation (GDPR) and other key legislation. Client information related to this is provided verbally at the start of the client relationship, in addition to which this entire entity is described in detail in the service provider's privacy policy. It will be available on the service provider's website (www.viisassusi.fi) by the end of September 2025.
2.8. Consideration of Regular and Other Feedback
A) At Flexio, feedback is logged in the client feedback system by either the client or any Flexio employee. Feedback is forwarded from the system to the quality contact person and the supervisor. The client or professional is contacted promptly and the issue is addressed collaboratively. In addition, based on regular feedback, Flexio plans development actions, and these are reviewed in team meetings, e.g., changes regarding general guidelines or operating methods. If the feedback or changes concern the service provider's operations, the person in charge discusses this with the service provider. General development actions can be communicated via email to all those working in the service unit.
A+B) The service provider uses the feedback they receive to develop their operations.
3. Self-monitoring Risk Management
3.1. Risk Management Responsibilities, Identification, and Assessment
A+B) The service provider is responsible for their company's risk management, identification and assessment. Risks related to data protection and privacy are considered in therapy work so that statutory patient records are only written to an electronic system approved as secure by Valvira, and in addition, the records are kept as short and general in nature as possible, without sensitive content. This approach ensures that, even if Brightlife experiences an unlikely data breach, clients' sensitive information remains protected from blackmail. Additionally, since other healthcare professionals can access the Kanta archive but may not need therapy details, confidentiality is maintained. Any paper notes or questionnaire forms are destroyed as data protection waste and Kela's rehabilitation decisions, etc., official documents are scanned as an attachment to the electronic system, after which the paper versions are similarly destroyed as data protection waste. The service provider gives clients clear information about their rehabilitation, therapy methods and effectiveness and explains treatment decisions in relation to each client's situation. This is done with respect for client choice, agency and consent, fostering collaboration, reducing conflict and encouraging client engagement in their care.
In therapy, risks include not only data security and privacy but also the therapist’s ability to interact ethically and professionally. Building a trusting relationship enables clients to explore personal challenges and adopt new perspectives, supporting positive behavioral changes. This process depends on a safe, confidential environment where clients can share openly without fear of repercussions and therapists maintain strict professional secrecy. Exceptions to the therapist's professional secrecy are statutory special situations (e.g., preventing immediate danger to life or serious endangerment of a minor child's growth and development), in which case the therapist first discusses the obligation to report with the client.
Challenging interactions, such as disappointments or misunderstandings, can occur in therapy and disrupt the relationship. Therapists should respond with openness, compassion and accountability while upholding boundaries to address these issues constructively and restore collaboration. Such ruptures, when handled well, can contribute to human growth and therapeutic progress.
3.2. Means for Addressing Problems and Deficiencies in Operations
A) Flexio's therapy center conducts an annual hazard and risk assessment, which is used to determine the corrective actions required for any identified deficiencies. For near-miss and hazardous situations, Flexio also has a separate Deviation System, where reports can be made regarding client, personnel and data security situations. These are handled monthly in the unit, and based on them, the required corrective measures are taken. If the deviation concerns the service provider, they are included in the process. Annually, resuscitation and rescue drills are also organized in the service unit, in which the service provider can participate at their own expense.
A+B) A central aspect of client safety involves validating the client's experience through open interaction to ensure their experience is acknowledged and its meaning can be collaboratively examined. If any deficiencies or issues are identified with the service provider, therapy premises or other essential factors, these are reviewed for operational improvement and any potential harm to the client is addressed. Clients or their representatives may provide feedback to the service provider either directly or via mail or email. In hazardous situations, all other operations are suspended and actions are taken to restore safety in accordance with established plans and protocols.
3.3. Monitoring, Reporting and Ensuring Competence in Risk Management
A+B) The service provider evaluates the services, premises and equipment in use, assessing potential risks and areas for development in connection to their operations. Identified risks are discussed with relevant parties, and operational changes are implemented when necessary to reduce risks. The service provider also addresses feedback regarding their operations promptly. They maintain professional competence by engaging in ongoing training, consulting scientific literature and staying informed about relevant regulations and best practices. Additionally, the service provider reviews their own professional competence, develops clinical skills and participates in regular supervision to support client work. Responsibilities also include ensuring personnel occupational well-being, safety, health care and insurance coverage as required by applicable regulations.
3.4. Purchased Services and Subcontracting
A+B) The service provider does not use purchased services or subcontracting in its operations.
3.5. Preparedness and Business Continuity Management
A) The service provider relies on Flexio's preparedness plan.
B) In a single-person therapy practice, continuity is at risk if the therapist becomes suddenly ill. Preventive measures include maintaining health and communicating promptly with clients in case of illness. Appointments may shift to remote sessions during minor illnesses if appropriate. For extended absences, clients are referred to colleagues with their agreement. In the event of IT disruptions, system provider instructions are followed.
4. Publication, Implementation, Monitoring and Updating of the Self-monitoring Plan
4.1. Implementation
A+B) This self-monitoring plan was updated and approved on 29.8.2025 (version 1.2). It takes effect immediately.
4.2. Publication, Monitoring of Implementation and Updating
A+B) The written self-monitoring plan is available at the service unit (Flexio's therapy center, Hämeenkatu 29 A 1, Tampere) and will also be published on the company's website (www.viisassusi.fi) by the end of September 2025. Additional information regarding self-monitoring can be requested from the person responsible for the service provider. The execution of the self-monitoring plan is regularly reviewed and any significant changes in operations are updated in the plan at least annually. The current version of the self-monitoring plan is accessible from both the service unit and the company's website.