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.
Personal data register of entrance examination for Bachelor´s degree programmes in International Business and Logistics and European Business Administration
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 personal data register of the entrance examination for Bachelor´s degree programmes in International Business and Logistics and European Business Administration of Metropolia University of Applied Sciences and the personal data it contains is to carry out selection of students for Bachelor´s degree programmes in International Business and Logistics and European Business Administration.
Legal basis for the processing of personal data:
The processing of the personal data contained in the personal data register of the entrance examination for Bachelor´s degree programmes in International Business and Logistics and European Business Administration of Metropolia University of Applied Sciences is based on:
- legal obligation to which the controllers are subject, in accordance with Universities of Applied Sciences Act (932/2014) and Act on the National Registers of Education Records, Qualifications and Degrees (884/2017).
- In addition, processing of the personal data is based on given explicit consent obtained from the data subject when the processing concerns special categories of the personal data such as biometric data (e.g. video material and voice in which persons are identifiable). These personal data are under the special protection in Article 9 of the EU’s General Data Protection Regulation.
The legal basis for the processing of personal data contained in the personal data register is not “legitimate interests”. Therefore, this section does not apply to register of the entrance examination for Bachelor´s degree programmes in International Business and Logistics and European Business Administration of Metropolia University of Applied Sciences.
The data subjects in the personal data register of the entrance examination for Bachelor´s degree programmes in International Business and Logistics and European Business Administration of Metropolia University of Applied Sciences are applicants participating in the entrance examination (e.g. students of Metropolia, employees of Metropolia).
The following personal data are stored in the entrance examination for Bachelor´s degree programmes in International Business and Logistics and European Business Administration of Metropolia University of Applied Sciences:
For each data category the register contains the following personal data:
1. DATA CONSERNING THE ENTRANCE EXAMINATION (APPLICANT’S BACKGROUND INFORMATION)
The application data is processed in the Studyinfo -service (Opintopolku.fi-palvelu), technically maintained by Finnish National Agency for Education's, before the entrance examination, during the entrance examination and after results of the examination have been confirmed. The following application data (background information) is collected:
- Basic data of the applicant: first names, nick name, last name, learned ID, identity number, email address and telephone number
- application identifier
- Information concerning date of the entrance examination
2. DATA CONCERNING IDENTIFICATION OF THE APPLICANT
- The applicant prepares to present his/her identification card during all steps of the application process (oral and visual interview on the web conferencing tool Zoom or Teams or by telephone).
- A passport, an identity card (Finnish or another EU country) or a Finnish driving license are acceptable proofs of the card holder’s identity. No other certificates will be accepted.
3. APPLICANT’S ANSWERS
- Preliminary assignments prior to the entrance examination will be returned via Moodle, email or E-form, depending on the Bachelor’s degree programme.
- Exam answers given in the entrance examination by E-form (are stored only on the server of Metropolia University of Applied Sciences).
- Logging data related to the entrance examination answers: the exact time the answer was saved (are stored only on the server of Metropolia University of Applied Sciences).
- Video interview (oral and visual interview on the web conferencing tool Zoom or Teams or by a telephone).The videos are recorded and stored in Metropolia network drive with access limited to staff members involved in the entrance examination / student selection process.
4. APPLICANT’S ENTRANCE EXAMINATION SCORE
The data processed at the end of the entrance examination and the data transmitted from Metropolia University of Applied Sciences to My -Studyinfo service (Opintopolku.fi-palvelu),is technically maintained by Finnish National Agency for Education:
- Applicant’s entrance examination score
Metropolia University of Applied Sciences stores the scores obtained from the data subjects (applicants) and these section-specific scores of the applicants’ entrance examination are transmitted to Studyinfo -service (Opintopolku.fi-palvelu).
The personal data is obtained from the Studyinfo -service (Opintopolku.fi-palvelu) regarding to participation in the entrance examination.
Applicants’ answers to the entrance examination are obtained from the data subjects themselves during the entrance examination.
Metropolia University of Applied Sciences stores the scores obtained from the data subjects (applicants).
Access to the personal data contained in the personal data register of the entrance examination for Bachelors´s degree in international Business and Logistics and European Business Administration of Metropolia 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 of the entrance examination for Bachelors´s degree in international Business and Logistics and European Business Administration of Metropolia, personal data processing agreements in accordance with Article 28 of the GDPR will be concluded by the xx unit/department with the following cooperation partners:
Eduix Oy and E-form software
E-form is used for collecting entrance examination assignments.
Funet Miitti / NORDUnet, service provider CSC Oy and Zoom web conferencing tool
Zoom is a web conferencing tool (Funet Miitti / NORDUnet, service provider CSC Oy). Zoom web conferencing tool is used to identify applicants and / or conduct group discussions or interview assignments. The Center for Science Information Technology - IT Center for Science - CSC's Funet Miitti (Zoom) service is used at Universities of Applied Sciences. The service has been implemented jointly in co-operation with NORDUnet and is therefore not part of the publicly available Zoom service. In addition, the Zoom service provided by NORDUnet operates entirely in the EU, in server environments reserved for NORDUnet's own use. These servers are located in Denmark and Sweden. The services have also been agreed with NORDUnet and Zoom, taking into account the requirements of European data protection regulations (GDPR).
Microsoft Corporation (part of the O365-package) Microsoft Teams web conferencing tool
Microsoft Teams web conferencing tool is used when an applicant prepares to present his or her ID in all parts of the entrance examination or in connection with an interview.
Doodle Ltd. and Doodle
Doodle is web conferencing tool is used when an applicant prepares to present his or her ID in all parts of the entrance examination or in connection with an interview.
Telephone
During a telephone interview, notes made from audio and video material can be collected. In addition, applicants for certain entrance examinations must be prepared for the exam that the supervisor of the examination is allowed to contact the applicant during the entrance examination with the telephone number provided by the applicant on the application via the Studyinfo -service (Opintopolku.fi-palvelu).
Email system
Instructions about the entrance examination process (for example, invitations to interviews, if the data subject has given his/her express consent for this processing activity) are sent by email through Outlook Exchange email system or with a security mail solution procured by Metropolia. Although Metropolia has procured the email system as part of the Microsoft O365 service package, the system is operated on Metropolia’s own server.
Deltagon Group Oy and security mail (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).
Finnish National Agency for Education and Studyinfo -service (Opintopolku.fi-palvelu)
Studyinfo -service (Opintopolku.fi-palvelu) maintained by the Finnish National Agency for Education, the preliminary assignments (pre-assignments) made via the E-form will be returned to StudyInfo -service (Opintopolku.fi-palvelu). Preliminary assignments are used in certain degree programmes.
In addition, the preliminary materials for group interviews of certain degree programmes are available on Studyinfo -service (Opintopolku.fi-palvelu). Metropolia University of Applied Sciences can be interpreted as the recipient of Studyinfo -service (Opintopolku.fi service) maintained by the Finnish National Agency for Education. The transfer is regulated by a transfer agreement (information service agreement) drawn up between Metropolia University of Applied Sciences and the Finnish National Agency for Education.
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 (dpo[at]metropolia[dot]fi); tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)) in a case considering international personal data transfers outside the EU or EEA.
The personal data collected for and processed within the personal data register of entrance examination for Bachelors´s degree in international Business and Logistics and European Business Administration of Metropolia are, as a general rule, stored in the register for a year from the date of the student selection decision.
The personal data in the register of applicants for higher education institutions is kept for five years, starting from the decision of student admission. Data concerning the right to study and National learner ID is kept forever. (Act on the National Registers of Education Records, Qualifications and Degrees 884/2017).
The following regulations have been also 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)
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 the personal data register of entrance examination for Bachelors´s degree in international Business and Logistics and European Business Administration of Metropolia University of Applied Sciences 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 has been obtained from the data subjects themselves regarding the application to higher education and participation in the entrance examination.
The personal data has also been obtained from Studyinfo -service (Opintopolku.fi-palvelu), maintained by the Finnish National Agency for Education, regarding the application to higher education and participation in the entrance examination.
Applying to the University of Applied Sciences as a student is arranged in such a way that when the applicant starts to fill in personal data of herself/himself through the Studyinfo -service (Opintopolku.fi-palvelu), the applicant will be informed in this connection that the personal data will be processed by the Finnish National Agency for Education and Metropolia University of Applied Sciences.
The personal data register of entrance examination for Bachelors´s degree in international Business and Logistics and European Business Administration of Metropolia University of Applied Sciences and the data contained in it will not be used in automated 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: Suvi Moll
Position: Head of degree programme in International Business and Logistics and European Business Administration
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: suvi.moll [at] metropolia.fi (suvi[dot]moll[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Suvi Moll
Position: Head of degree programme in International Business and Logistics and European Business Administration
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: suvi.moll [at] metropolia.fi (suvi[dot]moll[at]metropolia[dot]fi)
Contact details in questions concerning the purpose of the register:
suvi.moll [at] metropolia.fi (suvi[dot]moll[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.