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

Personal data register of Metropolia’s Healthy Boost Project

Data controller

Name

Metropolia University of Applied Sciences Ltd

Contact information

Metropolia University of Applied Sciences Ltd (Business ID: 2094551-1)
Postal address: P.O. Box 4000, FI-00079 Metropolia
Visiting address: Myllypurontie 1, 00920 Helsinki, Finland
Telephone (switchboard): +358 9 7424 5000

Person responsible for the register at the data controller

Name: Riitta Konkola
Position: President, CEO of Metropolia University of Applied Sciences

Person responsible for the content of the register:

Name: Arja Liinamo
Position: Project Manager
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: arja.liinamo [at] metropolia.fi

Contact details of the contact person for the register:

Name: Arja Liinamo
Position: Project Manager
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: arja.liinamo [at] metropolia.fi

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 purpose of the of the processing of data within the Metropolia UAS’s project register (partial project within EU Interreg Central Baltic, Baltic Sea Region Healthy Boost project), is to offer project partner cities in the BSR region, and any city inside EU, the digital tool for assessing their capacities for cross-sectoral cooperation for promoting health and well-being.

In general, Urban Labs for Better Health for All in the Baltic Sea Region – Boosting cross-sectoral cooperation for health and well-being in the cities - project (Healty Boost -project) is about cross-sectoral cooperation within cities and between city administrations, city residents and SMEs and other relevant stakeholders. The project is funded by Interreg Baltic Sea Region. Together with 14 partners from seven different countries, it seeks methods and tools to do cross-sectoral cooperation better for more holistic approach to health promotion. Information regarding the whole project is to be find on the project’s public web pages: http://www.healthyboost.eu/

The specific purpose of the processing of personal data within the Metropolia’s partial project (development and use of digital tool for self-assessment) is to analyse and further develop the use of Self-Assessment (SA) Tool. City administrations, including their multi-sectoral professionals and practitioners, are the end users of the digital self-assessment tool.

The idea is to enforce capacities for cross-sectoral cooperation for promoting health and well-being in the cities within Baltic Sea Region by the use of digital self-assessment tool. City administrations’ personnel will have access to the self-assessment tool (SA-tool) in the Healthy Boost project’s public web pages: http://www.healthyboost.eu/

In addition, anyone working as coordinator, manager or leader within a city involved with the project can share the link inside their city organization, in order to motivate people for assessing the cross-sectoral co-operation for promoting health and well-being in their city. After answering to questions in SA-tool, the person is able get feedback report by clicking the button ‘load the feedback report’ and then it is possible for the person to download the PDF-version of the report for herself/himself.

The feedback report shows graphically the persons results, also with the comparison of the replies to her or his own cities other replies and the whole assessment data gathered from all cities until that time. The report contains also verbal feedback by guidance and suggestions.

The tool will help city administrations to assess their capacities to work cross-sectorally for promoting health and well-being. The aim is societally beneficial.

Metropolia UAS, with other Healthy Boost project’s academic colleagues, will use the big, accumulated data, also for scientific research purposes. The research will be made by the rules of research ethics. Respondents and end users of the self-assessment tool can’t be identified. If, in addition to the whole data, the data is analyzed per cities, the anonymity of the individual cities is also preserved. Research use of the data allows to evaluate the status of cross-sectoral co-operation in the cities in EU region, which is a strong strategy in Europe for health and well-being promotion actions in the area as well as globally. The social benefit is obvious.

Legal basis for the processing of personal data:

The processing of the (personal) data contained in the data register of Metropolia’s Healthy Boost -project is based on consent (GDPR Article 6.1 a).

Partially, processing is necessary for the performance of a task carried out in the public interest (scientific research) (GDPR Article 6.1 e).

However, basically the collected data is not data related to an identified or identifiable person, as the collected data is related to the cities organizational activities.

Legitimate interests of the data controller or a third party

The legal basis for the processing of personal data contained in the personal data register of Metropolia’s Healthy Boost -project is not “legitimate interests”. Therefore this section does not apply.

Data recipients or recipient groups and regular disclosures

The data subjects of the Metropolia’s Healthy Boost -project register are the city administrations’ personnel - including their multi-sectoral professionals and practitioners - who will have access to the self-assessment tool (SA-tool) and who will use the SA-tool.

In other words, the end users of the digital self-assessment tool are the data subjects of the Metropolia’s Healthy Boost -project register.

In addition, anyone working as coordinator, manager or leader within a city involved with the project, can share the link inside their city organization, in order to motivate people for assessing the cross-sectoral co-operation for promoting health and well-being in their city. These possible end-users of the digital self-assessment tool are the data subjects of the Metropolia’s Healthy Boost -project register as well.

The following personal data might be stored in the personal data register of the Metropolia’s Healthy Boost -project register:

- email address of the end users of the digital self-assessment tool, if the end user has voluntarily given her/his email address for the service provider in order to get feedback on her/his performance

Regular sources of personal data

The personal data are obtained from the data subjects themselves.

Basically the collected data is not data related to an identified or identifiable person, as the collected data is related to the cities organizational activities.

Description of the groups of data subjects and personal data groups

The data collected for and processed within the personal data register of Healthy Boost project is using the following IT systems.

Personal data processing agreements in accordance with Article 28 of the GDPR have been concluded with the following IT system partners of Metropolia UAS:

Data Rangers Oy and Louhin tool/platform

The Louhin tool /IT-system is used by Healthy Boost -project in relation to Self-Assessment Tool data collection and feedback reporting.

Leijonaverkot Oy (part of Erillisverkot Group, former Deltagon Group Oy) and Deltagon’s sec@gw -security mail solution

Deltagon's sec@gw security e-mail solution can be used to forward sensitive personal data and confidential documents to e-mail addresses outside Metropolia (when e-mail is sent to a non-“@ metropolia.fi” e-mail address, or back to Metropolia), if needed.

Transfer of information outside the EU or EEA or to international organisations

Personal data contained in the personal data register of Metropolia's Healthy Boosty project will not be transferred outside the EU or EEA or to international organisations.

Although, the project has a Russian project partner, the collected data will not be given to this partner.

Personal data retention times

The data collected for and processed within the personal data register of Healthy Boost project is stored until the end of 2021. The project’s public web pages which will be maintained for 5 years after the project ends.

The following regulations have been observed when determining the retention times :

- EU General Data Protection Regulation (“GDPR”, 2016/679)

- Data Protection Act (1050/2018)

- Universities of Applied Sciences Act (932/2014)

- Decision of the National Archives of Finland on retention times – order given to universities of applied sciences concerning the permanent storage of data in electronic format (AL/20757/07.01.01.03.02/2016)

Rights of the Data Subject

The data subjects have the right to receive confirmation from the data controller of whether their personal data are being processed. Furthermore, the data subjects have the right of access to their personal data and the right to inspect their personal data stored in the register and to receive copies of them. Under the GDPR, the data controller must respond to requests by the data subjects to exercise their rights within one month of receiving such a request.

A. Right of access to personal data

The data subjects have the right to check whether their personal data are stored in the personal data register. A data subject may submit a request for information by delivering the data subjects’ information request form, which can be found on Metropolia’s public website and/or Metropolia’s intranet, to one of the three offices of Metropolia’s Student and Admission Services. The form must be filled in carefully, printed and signed personally by the data subject. If the data subject is a member of staff, they can deliver the request form to Metropolia’s Human Resources Management unit. When submitting the request, the data subject must prove their identity in a reliable manner (for example by presenting an official personal identity document or driving licence to the Metropolia employee receiving the request).

The visiting addresses of the offices of Metropolia’s Student and Admission Services are:

Metropolia’s Myllypuro campus

Myllypurontie 1, 00920 Helsinki, Finland

Metropolia’s Arabia campus

Hämeentie 135 D, 00560 Helsinki, Finland

Metropolia’s Myyrmäki campus

Leiritie 1, 01600 Vantaa, Finland

Metropolia’s Karamalmi campus

Karaportti 2, 02610 Espoo, Finland

The visiting address of Metropolia’s Human Resources Management unit is:

Metropolia’s Myllypuro campus (Buildings C and D, 5th floor)

Myllypurontie 1, 00920 Helsinki, Finland

All information requests will be forwarded from the offices of Metropolia’s Student and Admission Services and/or the Human Resources Management unit to Metropolia’s Data Protection Officer (email: tietosuojavastaava [at] metropolia.fi).

Metropolia’s Data Protection Officer will respond to information request submitted by the data subjects. If necessary, the Data Protection Officer can be requested to provide additional information on progress in the processing of the request or on the content of the response.

B. Right to rectify personal data and to restrict processing

The data subjects have the right to request the data controller to restrict the processing of their personal data in the following cases:

  • the data subject disputes the correctness of their personal data (right to rectify personal data), in which case processing will be restricted until the data controller can ascertain that the data is correct;
  • processing violates the law and the data subject objects to the erasure of their personal data, instead requesting that the processing of the data be restricted;
  • the data controller no longer needs the personal data for the purposes of the processing, but the data subject needs them in order to establish, exercise or defend a legal claim.

Such a request for rectifying personal data in a Metropolia personal data register or restricting processing can be submitted in person to one of the above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.

C. Right to erase personal data

The data subject has the right to obtain from the controller the erasure of their personal data from a Metropolia register without undue delay if any of the following conditions are met:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • the data subject withdraws consent on which processing is based and there is no other lawful basis for processing;
  • the personal data have been unlawfully processed; or
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

Such a request for the erasure of personal data in a Metropolia personal data register can be submitted in person to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.

D. Right to data portability (transfer of data from one system to another)

Partly applicable. Article 20 of the General Data Protection Regulation (GDPR) introduces a new right of data portability of a data subject. This right allows for data subjects to receive the personal data that they have provided to a data controller, in a structured, commonly used and machine-readable format, and to transmit those data to another data controller without hindrance. The new right to data portability aims to empower data subjects regarding their own personal data, as it facilitates their ability to move, copy or transmit personal data easily from one IT environment to another (whether to their own systems, the systems of trusted third parties or those of new data controllers).

In accordance with Article 20(1)(a) of the GDPR, in order to fall under the scope of data portability, processing operations must be based:

  • either on the data subject’s consent (pursuant to Article 6(1)(a), or pursuant to Article 9(2)(a) when it comes to special categories of personal data);
  • or, on a contract to which the data subject is a party pursuant to Article 6(1)(b).

The GDPR does not establish a general right to data portability for cases where the processing of personal data is not based on consent or contract.

Such a request pursuant to Article 20 of the GDPR can be submitted in person to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.

E. Right to not be subjected to a personal data breach

The data subject has the right to not be subjected to a personal data breach, as referred to in Article 33 of the EU’s General Data Protection Regulation, due to the data controller’s negligence in data protection and/or data security matters or due to negligence on the part of a data processor used by the controller in data protection and/or data security matters. The data subject has the right to be informed without undue delay if a personal data breach is likely to pose a high risk to the rights and freedoms of natural persons.

Right to Object

According to Article 21 of the EU’s General Data Protection Regulation, the data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) of Article 6(1) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), such as profiling based on these provisions. The data controller may no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

The request to stop processing of collected personal data can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity when submitting the request.

According to Article 21 of the EU’s General Data Protection Regulation, the data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) of Article 6(1) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), such as profiling based on these provisions. The data controller may no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

The request to stop processing of collected personal data can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services, where the data subject must prove their identity when submitting the request.

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 Metropolia (withdrawal request) can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services (or in the case of a member of staff, to the Human Resources Management unit), where 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
FI-00531 Helsinki

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 at Metropolia:

  • The data controller (Metropolia) 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 controller (Metropolia) 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 controller, Metropolia) 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 controller (Metropolia) 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 controller (Metropolia) 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 Metropolia.
  • The data are 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 data register of the project of Metropolia UAS 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 been collected from the data subjects themselves. It is voluntary to be registered in the personal data register of the Metropolia’s Healthy Boost project.

Automated individual decision-making, including profiling

The personal data register of Metropolia's Healthy Boost project and the data contained in it will not be used in automated decision-making or profiling.