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.
Metropolia’s Student Feedback Register
Suvi Väänänen, Metropolia’s Data Protection Officer
Email: tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi) phone: .+358 40 844 0690
Purpose of the processing of personal data:
The purpose of the processing of personal data in Metropolia’s Student Feedback Register is to enable Metropolia University of Applied Sciences to process the feedback given by the students. The forms of feedback consist of the feedback given by the students on learning, tuition, studying and the learning environments, as well as peer feedback. The degree programmes and Metropolia’s various functions may also use their own feedback procedures.
The purpose of obtaining feedback is to develop the operations of Metropolia University of Applied Sciences as a provider of UAS education. In addition, the feedback dialogue between the students and the staff forms a key element in Metropolia’s quality management. The students’ experiences of learning, studying and the learning environments are central to the development of activities in individual courses and the degree programmes, as well as at the level of the entire UAS.
This Privacy Notice for Metropolia’s Student Feedback Register is supplemented by the Privacy Notice for the UAS Graduand Feedback Questionnaire (AVOP).
Lawful basis for the processing of personal data:
The processing of the personal data contained in Metropolia’s Student Feedback Register is necessary for compliance with a legal obligation to which the data controller is subject (EU’s General Data Protection Regulation, Article 6(1)(c)). Metropolia University of Applied Sciences provides higher education in accordance with the Universities of Applied Sciences Act (932/2014), and feedback and the development of operations are important aspects when assessing the quality of this education.
In addition, the processing of personal data is partially based on the performance of a task carried out in the public interest (GDPR Article 6(1)(e)) and on the consent of the data subject (GDPR Article 6(1)(a)).
The lawful basis for the processing of personal data in Metropolia’s Student Feedback Register is not “legitimate interest”. Therefore this section does not apply.
The data subjects in Metropolia’s Student Feedback Register are the Metropolia students who give feedback. In addition, the data subjects include the lecturers, other members of staff and students who receive feedback as well as the lecturers’ supervisors who process feedback. Feedback concerning an individual person may only be processed by this individual themselves or by their immediate supervisor. Course feedback may be processed by the system administrator. In general, feedback may be processed by the designated person in charge of each survey, who must adhere to the principles concerning the processing of feedback given to individuals (by forwarding the feedback to the correct person, for example).
The following personal data are stored in Metropolia’s Student Feedback Register by personal data category:
CONTINUOUS FEEDBACK DURING THE COURSE
In addition to daily dialogue, continuous feedback can be given during a course through the OMA/Peppi system, which students can log into with their Haka ID (user ID and password). Once a student logs in with their Haka ID, they will become identifiable based on their login information. Feedback is given to the lecturer in each course’s workspace in the OMA/Peppi system through the “Give feedback to your lecturer” link, where the student selects the recipient(s). According to Metropolia’s guidelines, when students give personal feedback, they may only select the person (lecturer) whom the feedback concerns as the recipient. The guidelines also include information about best practices in giving feedback. The general principle is that feedback concerning an individual person may only be processed by this individual themselves or by their immediate supervisor. Numerical feedback assessing the implementation of a course is not considered personal data. The guidelines for this are attached to the “Give feedback to your lecturer” section in the OMA/Peppi system.
COURSE FEEDBACK IN THE OMA/PEPPI SYSTEM
The student (data subject) may give course feedback anonymously or using their own name (forename and surname) for each course in which they were accepted to study. The course feedback can be given by logging into the OMA/Peppi system with a Haka ID (the user ID and password of the data subject). In the OMA/Peppi system, the student is shown the courses which are about to be completed and for which they can give feedback. The course feedback function is made available one week before the course ends and will remain open for three weeks. The feedback is given anonymously, which means the persons giving feedback cannot be identified. Alternatively, the students may give feedback under their own name (forename and surname). Once the lecturer has responded to the feedback given by the group, this will appear in a message on the student’s desktop in the OMA/Peppi system.When the lecturer arranges for feedback to be given through the OMA/Peppi system, the course feedback section will appear on the students’ desktops. In this section the following forms of feedback are shown:
- Give feedback: Feedback forms for the courses for which feedback can currently be given.
- Feedback from the lecturer: The lecturer’s response to the feedback you have given concerning courses you have completed.
- Interim feedback: Open interim feedback questionnaires for courses. This is shown only if there are questionnaires available.
The course feedback includes the following information on the data subject (lecturer/student):
- The student’s replies to the questions concerning the assessment of the course, which consist of answers in the form of “I agree/I disagree” as well as the reasons under “Why?”.
- Open question section: This section may include personal data. However, it is not considered good practice to mention individual persons by name in the feedback questions or the open answers. The purpose is to give feedback on how the course was implemented rather than on individual persons.
- Open feedback section, which may also include personal data. However, it is not considered good practice to mention individual persons by name in the feedback questions or the open answers. The purpose is to give feedback on how the course was implemented rather than on individual persons.
The lecturer will receive a compilation of the feedback given at the end of the feedback period. After this, the lecturer will give the students feedback on their feedback as well as inform them of any measures taken based on their feedback.
If there are several lecturers holding the course, the open feedback will only be shown if all the lecturers assigned to the course have given permission for this to one another.
HowULearn SURVEY AND FEEDBACK TO THE STUDENT
HowULearn is a survey that provides information regarding students’ engagement and experiences in the teaching and learning environment at Metropolia. Once a student responds to the survey, they will receive personal feedback on their learning and studies. The HowULearn survey is conducted at a separately announced time.
The following data are recorded on the student (data subject) in the HowULearn survey:
Background information asked from the student themselves:
- Student number
- Email address
- Gender
- Year of birth
- Previously completed degree
- Degree programme, including the major subject or specialisation option
- Form of education
- Possible status as an exchange student
- Start year of current studies
- Number of credit points at the time of responding
- Previous studies at universities of applied sciences or universities
- Stage of the studies
- Work experience (paid work)
Basic information on the student:
- Student number, forename and surname, gender, nationality, native language and language used
The student’s rights to study:
- Information on the student’s field of study, degree programme, specialisation option and major subject
Courses completed by the student:
- Scope in credit units or credit points
FEEDBACK ON FEEDBACK EVENT
Every year, the degree programmes arrange a joint event for students and staff where the participants discuss the feedback received by the degree programme and the development work carried out based on this feedback. The participants may give oral general feedback to the different lecturers in the degree programme.
A memorandum is prepared at the event and saved in the joint compilation chart in the Feedback on Feedback Teams channel. This compiled memorandum does not include identifiable personal data. The workspace in the Feedback on Feedback Teams channel also contains the memos for the previous years’ events.
FEEDBACK SURVEY OF METROPOLIA’S JOINT SERVICES (NOT IN USE)
Metropolia’s services collect feedback from the students at the beginning of every other year using an online form. Feedback is requested on the activities of the following services: IT Services, Student Affairs, Library and Information Services, International Services, Student Wellbeing Services and Communications and Marketing. The feedback helps the services to develop according to the students’ needs. Feedback can be given anonymously or with the giver’s details (forename and surname of the student/lecturer/other member of staff, student’s student number).
NATIONAL CAREER MONITORING SURVEY
The Career Monitoring Survey is organised annually for students who graduated five years earlier. The purpose of the survey is to find out about the careers of those who have graduated from universities of applied sciences, the situation in the labour market and the graduates’ satisfaction with their degrees. Some of the questions are also used as a qualitative indicator of the employment of UAS students. The privacy notice of Metropolia’s National Career Monitoring Survey has been published on Metropolia’s public website under Privacy Notices in the Data Protection and GDPR section.
PLACEMENT MONITORING (the survey has been discontinued but previous results are available for viewing in Metropolia’s OMA intranet)
The employment of Metropolia graduates in the labour market was monitored with a placement monitoring survey, which was conducted in cooperation with a number of other UASs and universities. The graduates were surveyed one year after their graduation. The survey’s key aim was to find out about the graduates’ current job description and how well their education had met the needs of working life. It was possible to respond to the survey either using a form sent by post or using an online form. For the purpose of conducting the placement monitoring, Metropolia University of Applied Sciences had saved the forename and surname, year of graduation and address information of its graduates. The compilations of the placement monitoring do not include personal data.
STUDENT SATISFACTION SURVEY for 2nd year students (the survey has been discontinued but previous results are available for viewing in Metropolia’s OMA intranet)
Feedback was collected from Metropolia’s second-year students on their satisfaction with their studies and the support services. The survey was conducted once a year in the autumn term. The focus was on the support services’ questions, which they used to monitor their success in achieving their goals and addressing their focus areas. The survey also included joint questions concerning teaching. The survey was used to find out about the students’ experiences and satisfaction in their early-stage studies and in Metropolia’s various support services. The feedback data is utilised widely in the degree programmes and joint functions as well as by Metropolia’s management. The surveys were conducted by sending a link to the survey questionnaire by email to selected students. The following personal data of the data subjects were stored when they responded to the survey: forename, surname and email address. The survey compilations did not contain any personal data.
National UAS Graduand Feedback Questionnaire (AVOP)
This Privacy Notice for Metropolia’s Student Feedback Register is supplemented by the Privacy Notice for the UAS Graduated Feedback Questionnaire (AVOP). The National UAS Graduand Feedback Questionnaire (AVOP) is used by the Ministry of Education and Culture to collect feedback from the graduating students of all universities of applied sciences in Finland. The AVOP questionnaire is sent to students graduating with a UAS Bachelor’s degree or a UAS Master’s degree. The questionnaire contains questions on seven areas: background information, teaching and learning, international studies, multiculturalism and language studies, contacts with workplaces and working life advice, work placement, final project and student satisfaction. A graduating student can start completing their graduation notification on their personal desktop at https://oma.metropolia.fi/ by selecting Applications and Graduation. The graduation process starts by responding to the AVOP questionnaire. Users can log in to the AVOP questionnaire with their Haka ID at https://avop.fi/en . After answering the AVOP questionnaire, the student will be shown a link leading to the graduation notification form at the end of the questionnaire. If the student does not fill in the graduation notification form immediately after responding to the survey, they must save the graduation notification link from the AVOP questionnaire in order to be able to complete the notification later. The link to the privacy notice for the AVOP questionnaire was presented at the top of this section ( This Privacy Notice for Metropolia’s Student Feedback Register is supplemented by the Privacy Notice for the UAS Graduated Feedback Questionnaire (AVOP)).
The Privacy Notice for the UAS Graduand Feedback Questionnaire (AVOP) provides information on the personal data collected by personal data category.
The material concerning those who respond to the AVOP questionnaire of Metropolia University of Applied Sciences is transferred to Metropolia’s database using the ArvoAPI interface, and the degree programme and major subject for all respondents are linked to the material, after which the data are anonymised. In addition, data on groups of fewer than five respondents are not shown in reporting.
AVOP2 questionnaire for second-year students
The aim of the AVOP2 questionnaire is to find out about the experiences of Metropolia’s second-year students in learning, studying and tuition at Metropolia using the same indicators as in the national AVOP questionnaire. The results of the survey are used for developing education.
The following data are recorded on the student (data subject) in the AVOP2 questionnaire:
Background information asked from the student themselves:
- Gender
- Age
- Previously completed degree
- Degree programme
The survey is conducted annually. The results of the survey are reported in a way that no individual respondent can be identified. The material is processed solely by a person assigned to the task.
CONSENT FOR AND INFORMATION ON CERTAIN ACTIONS
- Before giving feedback, the data subjects (students, lecturers or other members of Metropolia staff) are asked for their consent, and by giving their consent for the processing of their personal data and feedback, they accept that once they enter information on the feedback form they will become involved in measures that concern communications to the giver and receiver of the feedback. In addition, in the course feedback in OMA, if there are several lecturers holding the same course (team tuition), consent is required from each lecturer separately concerning giving access to open feedback to the other lecturers on the course. Consent is given by checking the appropriate box on the “Feedback questions” tab in the course feedback section in OMA.
- Feedback concerning an individual person may only be processed by this individual themselves or by their immediate supervisor.
- Information on consent concerning measures targeted at the data subjects of Metropolia’s Student Feedback Register (students, lecturers and other staff): e.g. consent to receiving email related to activities.
- Email reminder sent to the lecturer concerning missing course feedback questions in OMA: The lecturer will receive a reminder about preparing their feedback questions.
- Email reminder sent to the student concerning course feedback in OMA: The student will receive a reminder about responding to the course feedback questionnaire.
- Compilation of course feedback in OMA sent to the lecturer: The lecturer can print the course feedback they have received for a period of their choice.
The personal data are obtained from those who give and receive feedback.
Metropolia’s Student Feedback Register is a personal data register based on voluntary participation.
Access to the personal data contained in Metropolia’s Student Feedback Register 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 Metropolia’s Student Feedback Register, personal data processing agreements in accordance with Article 28 of the GDPR have been or will be concluded with the following cooperation partners:
CSC – IT Center for Science Ltd; Haka trust network identification system
CSC – IT Center for Science Ltd. is the administrator of the Haka trust network. The Haka trust network is used in the joint services of the higher education institution community provided by CSC to identify the student.
Eduix Oy; OMA/Peppi system (owned by Metropolia jointly with TAMK, but maintenance and development services are obtained from Eduix Oy)
The role-specific desktop in Metropolia’s OMA/Peppi system allows the lecturers to create feedback forms for the students, and enables the students to give feedback using these forms. Metropolia’s students, lecturers and other staff have user rights (a user ID) to the OMA/Peppi system. The OMA/Peppi system is owned by Metropolia University of Applied Sciences together with Tampere University of Applied Sciences (TAMK) (currently Tampere University of Applied Sciences and Tampere University form the multidisciplinary Tampere universities community, https://www.tuni.fi/en). However, the maintenance and development services for the OMA/Peppi system are procured from Eduix Oy.
Microsoft Corporation; Teams online videoconferencing tool (part of the Microsoft O365 package)
A memorandum is prepared at the Feedback on Feedback events and saved in the joint compilation chart in the Feedback on Feedback Teams channel (in the folder for the Microsoft Teams online videoconferencing tool). The workspace in the Teams channel also contains the memos for the previous years’ events.
Eduix Oy; E-lomake (E-form) software
The E-lomake software has been used for conducting feedback surveys.
CSC – IT Center for Science Ltd; ArvoAPI interface
ArvoAPI is an additional service provided by CSC with the aim of improving the quality and usability of collected feedback data. Responses to the AVOP questionnaire are transferred through the ArvoAPI interface to the databases of Metropolia University of Applied Sciences and combined with information on the major subject and degree programme of every respondent. After this, the data are anonymised.
As a general rule, the personal data contained in Metropolia’s Student Feedback Register are not transferred outside the EU or EEA or to international organisations.
The personal data contained in the register may be transferred outside the EU or EEA for the provision of IT services that are necessary for working or completing studies, based on a case-by-case consideration. The state to which personal data are transferred is the United States. It is also possible that personal data may be transferred to, for example, India, a country where global ICT service providers frequently base their help desk operations or ICT user support functions.
The international transfer of personal data from a personal data register of Metropolia University of Applied Sciences to the United States and/or elsewhere outside the EU or EEA is secured primarily with measures, i.e. Standard Contractual Clauses, provided for in Chapter V, Article 46 of the EU’s General Data Protection Regulation (GDPR). The Standard Contractual Clauses are included in agreements with ICT service providers concerning the processing of personal data.
Only the necessary data are transferred and the transfer is carried out in accordance with data protection legislation and within the restrictions placed by it. A separate agreement is always concluded on data security during the transfer.
As a general rule, the personal data collected and processed in Metropolia’s Student Feedback Register are retained for the duration of the processing, after which the personal data concerning the data subjects are erased, unless they are required to be stored permanently.
Some of the course feedback must be stored permanently. Data that must be stored permanently include summaries and compilations of feedback as well as feedback statistics.
The retention time is based on Metropolia’s archiving plan.
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.
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 protection of the register has been agreed upon with the system providers. If necessary, the responsibilities have been described in adequate detail in the appropriate agreements.
- The employees and other personnel 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) 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 have 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 for processing in Metropolia’s Student Feedback Register 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 were obtained.
Metropolia’s Student Feedback Register is a personal data register based on voluntary participation and used for managing the feedback given in surveys concerning tuition, job satisfaction and job wellbeing as well as other activities at Metropolia.
No one is obliged to join Metropolia’s Student Feedback Register. Consent is given voluntarily.
The personal data stored in the register have been collected in connection with feedback from the persons giving it, as well as from the persons receiving it if they provide a response to the feedback. In addition, if there are several lecturers holding the same course (team tuition), open feedback given to one lecturer will not be shown to the other lecturers unless every lecturer receiving feedback gives their express consent to this.
The personal data in Metropolia’s Student Feedback Register are not used for automated individual decision-making or profiling.
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: Heidi Rontu
Position: Vice President, Education
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: heidi.rontu [at] metropolia.fi (heidi[dot]rontu[at]metropolia[dot]fi)
Contact details of the contact person for the register (OJP feedback):
Name: Tiina Kokko
Position: Specialist /Renewable Learning/ Lifelong Learning Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: tiina.kokko [at] metropolia.fi (tiina[dot]kokko[at]metropolia[dot]fi)
Contact details of the contact person for the register (HowULearn feedback):
Name: Jenni Koponen
Position: Principal Lecturer, Lifelong Learning Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: jenni.koponen [at] metropolia.fi (jenni[dot]koponen[at]metropolia[dot]fi)
Contact details of the contact person for the register (AVOP, AVOP2 and Uraseuranta -feedback):
Name: Kirsi Kuosa
Position: Specialist /Renewable Learning/ Lifelong Learning Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: kirsi.kuosa [at] metropolia.fi (kirsi[dot]kuosa[at]metropolia[dot]fi)
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.
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 (tietosuoja[at]om[dot]fi)
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 (tietosuojavastaava[at]metropolia[dot]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.