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EU Data Act

The Data Act is new EU legislation with the purpose of making it easier for customers to move from one vendor to another, related to data services, in general. Here is a description from the EU.

“In order to ensure a competitive market in the EU, customers of data processing services (including cloud and edge services) should be able to switch seamlessly from one provider to another. However, customers currently face a number of barriers to this, including high charges associated with, for example, data egress, lengthy procedures and a lack of interoperability between providers that can result in a loss of data and applications.

The Data Act will make switching free, fast and fluid. This will benefit customers, who can freely choose the services that best meet their needs, as well as providers, who will benefit from a larger pool of customers.”

The main subjects to be addressed by the Data Act is

  • Easy termination rights, meaning no long binding contracts and expensive termination fees.

  • Easy export of data and open interfaces

  • Possibility for parallel use of systems

  • Online information about what and how to export

  • Contractual clauses in line with the Data Act requirements

From 12 September 2025, certain chapters of the Data Act are applicable to providers of “data processing services”, including Software as a Service (SaaS) providers.

Identum AS, as a vendor of SaaS based IAM solutions, will be affected by the Data Act and will comply with the requirements. As Norway is not a part of the EU, it is unsure when this will become applicable through the EEA agreement. It will be applicable for our business in Sweden, Denmark, Finland and Netherland from 12 September 2025. The Data Act is as well applicable to vendors delivering services to EU based companies.

That said, when it comes to advanced business software, switching from one vendor to another is far more complex than the hurdles that are removed by the Data Act. The complexity related to integrating a business solution like an IAM system into the IT-infrastructure of an organisation, will usually require planning and competent resources.

Below you will find a summary of the Data ACT requirements, and how we are ensuring to comply with them.

Contract terms

Contracts terms will reflect relevant Data ACT legislation terms and conditions. We have published an addendum to the Identum Terms of Service for the Data Act. The Addendum will automatically be activated for all our customers. The addendum is published online, and details out the topics below. See this link for the Identum Terms of Service Data Act addendum: View document here.

Termination rights and early termination fees

The Data Act requires that customers can switch vendors with a notice period of down to two months. For new and existing customers, Identum's contracts include a two-month notice period for termination. If a contract has a specified minimum term, and the customer chooses to terminate early, they will be responsible for the remaining value of the contract.

We do not charge any separate early termination fees, apart from the costs directly related to the switching process. Customers are required to pay for their current usage and the invoice period. This ensures our compliance with the Data Act while maintaining clear and fair terms for our customers.

Description on what you can export and how to export

Our online documentation does describe both how and what you can export. Links to this documentation are included in the contract addendum mentioned above. The data will be available in a common machine readable format like CSV or Excel/Google sheet open format. See description in Appendix A below:

Open interfaces

We already provide online documentation for all our APIs, and customers are free to use them for any purpose not violating our terms of service.

Sub-processors

An overview over our sub-processors and their jurisdiction can be found in Visma Trust Centre.

Securing your data

Information regarding technical, organisational and contractual measures implemented in order to prevent international governmental access to non personal data can be found in the following privacy statement.

Appendix A

eADM Data Export

All registered source data for a user can be exported from eADM into a CSV file, which can be used for further processing in applications like Microsoft Excel. You have the flexibility to export data for individual users, all users, or a filtered selection based on permissions, departments, or other rules.

When exporting, you can select the specific attributes you want to include in the CSV file. A comprehensive list of available attributes is available in the documentation. It is important to handle the exported file, which may contain personal data, in accordance with your organisation's internal guidelines and current data protection legislation.

Knowledge base article: How to Export User Data to a CSV file

List a) Exportable data:
User and Employment Data
  • Ansattnummer

  • ABusiness Number

  • ACompany

  • ACostCentre Name1

  • ACostCentreName2

  • ACostCentre Name3

  • AEmployeeNumber

  • Alocation

  • APositionCodeld

  • APositionld

  • APositionManager

  • AQualificationCode

  • AServicePlaceName

  • AShiftWark

  • AUserid

  • AWeekly Hours

  • AYearly Hours

  • Adresse, privat

  • Adresse, privat: Gateadresse

  • Adressise, privat: Postnummer:

  • Adresse, privat: Poststed

  • Adresselinje 1

  • Adresselinje 2

  • Ahourly Wages

  • Alle avdelingsnummer

  • Alle stillingskoder

  • Alle stillingstyper

  • AlternateDepartment

  • Ansatt ID -Visma brukeradministrasjon

  • Ansattkategori

  • Ansvar

  • Aproject

  • Arbeidsoppgaver

  • Arbeidstype

  • AtitleSsb

  • Avdeling

  • Avdelingsleder

  • Aulelemmer

List b) Non-exportable data:
  • Access logs

  • System settings

  • Configuration parameters

eFEIDE Data Export

eFEIDE is an Identity and Access Management (IAM) platform for the Norwegian education sector that automates the lifecycle of user accounts by synchronising data from school administrative systems.

All registered data for a user in the eFEIDE system can be exported from eFEIDE as a CSV file. This allows you to export data for individual users, all users, or a filtered selection based on school, department, and date. When exporting, you can select the specific attributes you wish to include in the downloaded CSV file.

Knowledge base article: Eksportere brukerdata fra eFEIDE

List a) Exportable data:
User and Employment Data
  • Id

  • First name

  • Last name

  • Social Security Number (SSN)

  • E-mail

  • Phone number

  • Username

  • First time password

  • Role

  • Group

  • School

List b) Non-exportable data:
  • Access logs

  • System settings

  • Configuration parameters

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