This Privacy Notice is based on the EU's General Data Protection Regulation (2016/679, “GDPR”), namely the obligation to inform the data subjects (GDPR Articles 12–14), the data controller's obligation to maintain a record of processing activities under its responsibility (GDPR Article 30), as well as the obligations set out in the Finnish Data Protection Act (1050/2018) supplementing the GDPR.
Additionally, this Privacy Notice has been prepared with the aim of making it accessible in accordance with the requirements of the EU's Web Accessibility Directive (Directive (EU) 2016/2102 of the European Parliament and of the Council on the accessibility of the websites and mobile applications of public sector bodies) and the Finnish Act on the Provision of Digital Services (306/2019) supplementing it.
Name of the register
Customer Register of the 3UAS-libraries
- Haaga-Helia University of Applied Sciences Ltd
- Laurea University of Applied Sciences Ltd
- Metropolia University of Applied Sciences Ltd
Haaga-Helia University of Applied Sciences Ltd
(Business ID: 2029188-8)
Ratapihantie 13, 00520 Helsinki
Laurea University of Applied Sciences Ltd
(Business ID: 1046216-1)
Ratatie 22, 01300 Vantaa
Metropolia University of Applied Sciences Ltd
(Business ID: 2094551-1)
Myllypurontie 1, 00920 Helsinki
Contact details of the contact persons for the register:
Name: Eeva Klinga-Hyöty
Position: Head of Information Services
Address: Haaga-Helia University of Applied Sciences Ltd, Ratapihantie 13, 00520 Helsinki
E-mail: eeva.klinga-hyoty [at] haaga-helia.fi
Name: Hanna Lahtinen
Address: Laurea University of Applied Sciences Ltd, Ratatie 22, 01300 Vantaa
E-mail: hanna.lahtinen [at] laurea.fi
Name: Hellevi Hakala
Position: Head of Information Services, Library and Information Services
Address: Metropolia University of Applied Sciences Ltd, Myllypurontie 1, 00920 Helsinki
E-mail: hellevi.hakala [at] metropolia.fi
Controllers’ data protection officers:
teija.aarnio [at] haaga-helia.fi
Tel. 040 488 7001
marjo.valjakka [at] laurea.fi
Tel. 046 856 7658
tuulia.aarnio [at] metropolia.fi
Tel. 050 565 8499
Requests concerning the exercising of the data subject’s rights should be addressed to the controller’s data protection officer of the organization it may concern.
Data Protection Officer
Riikka Ikäheimonen, Metropolia’s Data Protection Officer
Tel: +358 50 565 8499
Email: tietosuojavastaava [at] metropolia.fi
Purpose and legal basis of the processing of personal data
Purpose of the processing of personal data:
The 3UAS-libraries are joint libraries of the following universities of applied sciences:
- Haaga-Helia University of Applied Sciences
- Laurea University of Applied Sciences
- Metropolia University of Applied Sciences
Personal data is handled for the purpose of taking care of the controllers’ customer relationships. The controllers process the data as well as subcontracting parties to process the data on the controllers’ behalf.
Legal basis for the processing of personal data:
The lawfulness of processing personal data is based on the following principles of the EU General Data Protection Regulation:
- Processing is necessary for compliance with a legal obligation to which the controller is subject (GDPR Art. 6 (1)c);
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party (GDPR Art. 6 (1)f);
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes (GDPR Art. 6 (1)a), or, in the case of special categories of personal data, the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in the regulation may not be lifted by the data subject (GDPR Art. 9 (2)a).
Legitimate interests of the data controller or a third party
The legitimate interests of the controllers are based on a meaningful and appropriate relationship between the data subject and the controllers, which arises when the data subject uses the services of the library, as long as the processing is done for purposes which the data subject can reasonably be assumed to have expected at the time of, and in conjunction with, the data being collected.
Data recipients or recipient groups and regular disclosures
The data subjects in the customer register of the 3UAS-libraries are customers using the services of the 3UAS-libraries.
For each data category, the register contains the following personal data, considered legitimate:
BASIC PERSONAL DATA
- customer's name
- personal ID
- telephone number
- email address
- student number
DATA RELATED TO CUSTOMER RELATIONSHIP
- library card number, PIN code
- language of business
- customer and statistical category
- acceptance or denial of use of self-service collection
- information on late fees and related measures
- long loan times
- date of last update of customer details
- existing library loans and reservations
Regular sources of personal data
Personal data is primarily collected from the data subjects themselves.
Data in the register is also collected from other sources in the public domain (e.g. publicly available address and telephone directories).
Additionally, data is obtained from other registers owned by the controllers (e.g. the student administration data file).
Moreover, the controllers store personal data generated during the customer relationship.
Description of the groups of data subjects and personal data groups
Access to the personal data contained in the customer register of the 3UAS-libraries will be given, where necessary, in the systems listed below. (For the purpose of repairing a technical fault, for example, access will be given with administrator rights to the system provider or to the maintenance personnel of a measurement device.) All system/equipment/software providers used (the companies behind them) can be deemed to be recipients of personal data and recipients of regular disclosures from the register.
With respect to the systems used by the register, personal data processing agreements in accordance with Article 28 of the GDPR will be concluded with the following cooperation partners:
Lowell Suomi Ltd (Debt collection agency)
The handling of the overdue fees is transferred to a debt collection agency Lowell Suomi Ltd.
Eduix Ltd and e-forms
E-forms are used for collecting requests for order a book for loan and customer’s notices of changes of contact details for the library.
Tuudo Ltd and Tuudo
Tuudo is a mobile application which allows students to view their own credits, enroll in teaching and manage their personal study schedules. Metropolia University of Applied Sciences and Student Union METKA has agreed on the technical maintenance of METKA student union’s membership register so that Metropolia University of Applied Sciences will carry out maintenance.
It has been agreed between Metropolia University of Applied Sciences and METKA student union that it is possible to retrieve information directly from Metropolia University of Applied Sciences' student and study information system using the TUUDO service and the TUUDO mobile application. The student can utilize the information made possible by this connection when using the TUUDO service and the TUUDO mobile application.
The mobile application (Tuudo) provides the student with METKA’s digital membership ID which allows the student to take advantage of METKA’s membership benefits and services. The use of Tuudo service in order to view student’s own credits, is based on student's voluntary joining as a member of METKA student union.
Transfer of information outside the EU or EEA or to international organisations
As a general rule, personal data contained in the personal data register of the xx activities / project of Metropolia will not be transferred outside the EU or EEA or to international organisations.
However, personal data contained in the personal data register may be transferred outside the EU or the EEA in order to provide IT services necessary for work or study, on a case-by-case basis. The destination country to which the personal data is transferred then, is mainly the United States. It is also possible that India is the destination country as global ICT service providers use often India as a host country for the international helpdesk service / ICT technical user support. International transfers of personal data from the Metropolia University of Applied Sciences' personal register to the United States and / or elsewhere outside the EU / EEA are primarily secured then by the safeguard provided for in Article 46 of Chapter V of the EU General Data Protection Regulation (GDPR), standard contractual clauses. The SCC (Standard Contractual Clauses) clauses will be included as part of the personal data processing agreement to be drawn up with the ICT service provider. Only the necessary data will be transferred and the transfer will be made in accordance with and within the limits set by data protection law. The security and data protection of the transfer are always agreed separately.
(-> If you use IT systems, softwares etc. provided by IT service provider registered in United States /outside the EU/EAA, it might be possible that the IT service provider uses servers for the data storage located in United States /outside the EU/EEA -> This might mean that personal data will be transferred to United States/ outside the EU/EEA as the storing of personal data is considered as processing of personal data according to the GDPR, and as storing personal data into the data storage servers located outside the EU/EEA, is considered as transferring personal data outside the EU/EEA according to the GDPR).
If that is the case, you need to specify to which third countries outside the EU or EEA you are transferring personal data (list of countries/mapping of countries).
When mapping transfers, do not forget to also take into account onward transfers, for instance whether your processors outside the EEA transfer the personal data you entrusted to them to a sub-processor in another third country or in the same third country. In other words, you must know where the personal data you exported may be located or processed by the importers (map of destinations).
Keep in mind that remote access from a third country (for example in support situations) and/or storage in a cloud situated outside the EEA, is also considered to be a transfer. More specifically, if you are using an international cloud infrastructure you must assess if your data will be transferred to third countries and where, unless the cloud provider clearly states in its contract that the data will not be processed at all in third countries.
As a next step, you must identify the transfer tools (safeguards) you are relying on amongst those described in the Chapter V of the GDPR (Articles 45 - 49).
Article 46 of the Chapter V of the GDPR lists standard contractual clauses (SCCs) as a transfer tool containing “appropriate safeguards” for the data transfer.
Whatever GDPR transfer tool you choose, you must ensure that, overall, the transferred personal data will have the benefit of an essentially equivalent level of protection. “An essentially equivalent level of protection” means that the transferred personal data is afforded a level of protection in the third country that is essentially equivalent to that are guaranteed in the EEA where strict data protection legislation prevails.
It might be useful to contact Data Protection Officer of Metropolia UAS (dpo [at] metropolia.fi (); tietosuojavastaava [at] metropolia.fi ()) in a case considering international personal data transfers outside the EU or EEA.
Personal data retention times
The personal data in the register is only stored for as long as and to the extent that each category of data is needed, proportionate to the purpose of processing of the personal data. Additionally, the duration of storage of personal data complies with possible statutory requirements.
Customer details are erased annually where applicable. Customer relationships are erased completely around three (3) years after the last loan event.
The data controllers regularly evaluate the need for storing data in accordance with their internal practices.
Right to withdraw consent
If the processing of personal data is based on the data subject’s consent, the data subject has the right to withdraw their consent for processing at any time without the withdrawal of consent affecting the lawfulness of processing based on consent before its withdrawal.
The withdrawal of consent for the processing of personal data collected by the register (withdrawal request) can be submitted to the organization it may concern. The data subject must prove their identity when submitting the request.
Right to lodge a complaint with a supervisory authority
Every data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of their personal data infringes the applicable data protection regulations.
The national supervisory authority in Finland is the Office of the Data Protection Ombudsman. Contact details:
Office of the Data Protection Ombudsman
Street address: Lintulahdenkuja 4, 00530 Helsinki, Finland
Postal address: PO Box 800
Telephone (switchboard): + 358 29 56 66700
Fax: + 358 9 56 66735
Email: tietosuoja [at] om.fi
Registry Security Principles
General description of the technical and organisational security measures aiming at protecting the personal data of the data subjects and the personal data registers:
- The data controllers and the system providers have agreed on the protection of the register. If necessary, the responsibilities have been described in adequate detail in the appropriate agreements.
- The employees and other personnel of the data controllers have undertaken to comply with the obligation of secrecy and to keep confidential the information they receive in connection with the personal data processing.
- The system providers (personal data processors that act on behalf of the data controllers) undertake to maintain the register and the personal data relating to it in accordance with good data processing practices and comply with the obligation to absolute secrecy and confidentiality.
- The data security of the personal data register of the data controllers and the confidentiality of the data contained therein are ensured with appropriate technical and administrative means in accordance with good data processing practices.
- The data controllers has restricted user rights and authorisations to data systems, tools and other storage platforms in such a way that they can only be accessed and processed by the persons who are necessary for such processing due to their job duties or position.
- The system containing personal data may only be used by employees who are entitled to process personal data due to their job duties and/or position. Such employees will be given the appropriate training for their duties.
- Every user of a tool/system must identify themselves with their personal codes, which are issued when the right to access the tool/system is granted. The right of access will expire once the employee resigns or is transferred from the duties for which they were granted the right at Haaga-Helia, Laurea or Metropolia.
- The data is collected in databases that are protected logically and physically.
- The databases and their back-up copies are located in locked premises, and the data can only be accessed by certain pre-appointed persons.
Information on whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequen
Information on whether the provision of personal data for processing in the customer register of the 3UAS-libraries is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data. An account has been given for each register regarding how the personal data was obtained.
The personal data stored in the register has mostly been collected from the data subjects themselves. Additionally, data is obtained:
- from other sources in the public domain (e.g. publicly available address and telephone directories)
- from other registers owned by the controllers (e.g. the student administration data file)
- the controllers store personal data generated during the customer relationship
Automated individual decision-making, including profiling
The customer register of the 3UAS-libraries and the data contained in it will not be used in automated decision-making or profiling.