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 Degree Program in Nursing (Edunation Applicants)
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: Päivi Haarala
Position: Head of department
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: paivi.haarala [at] metropolia.fi (paivi[dot]haarala[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Nea Lehtimäki
Position: Degree coordinator
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: nea.lehtimaki [at] metropolia.fi (nea[dot]lehtimaki[at]metropolia[dot]fi)
Contact details in questions concerning the purpose of the register: nea.lehtimaki [at] metropolia.fi (nea[dot]lehtimaki[at]metropolia[dot]fi)
Sanna Saarnia, Metropolia’s Data Protection Officer
Email: tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)
Purpose of the processing of personal data:
The purpose of the personal data register of entrance examination for degree program in nursing (Edunation applicants) is to carry out selection of the students for the degree program in nursing for applicants who apply through Edunation. Edunation is an education export and consultation company, which purchases education services from Metropolia University of Applied Sciences.
Legal basis for the processing of personal data:
The processing of the personal data contained in the personal data register of entrance examination for degree program in nursing (Edunation applicants) of Metropolia University of Applied Sciences is based on:
The data subjects consent to the processing of their personal data for one or more specific purposes.
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), the processing of the personal data is based on given explicit consent obtained from the data subject. These personal data are considered ‘sensitive’ and are under the special protection in Article 9 of the EU’s General Data Protection Regulation.
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).
The legal basis for the processing of personal data contained in the personal data register of entrance examination for degree program in nursing (Edunation applicants) of Metropolia University of Applied Sciences is not “legitimate interests”. Therefore, this section does not apply.
The data subjects in the personal data register of entrance examination for degree program in nursing (Edunation applicants) of Metropolia University of Applied Sciences are applicants who participate the entrance examination.
The following personal data are stored in the personal data register of entrance examination for degree program in nursing (Edunation applicants) of Metropolia University of Applied Sciences:
BASIC INFORMATION AND CONTACT DETAILS
- Full name
- Gender
- Date of birth
- Email address
- Nationality
- Passport number (for the purpose of identifying the applicant before the examination)
Data is given by the data subjects and delivered by Edunation through security email approximately 1 week prior to each entrance examination. Data will be stored in the secured network drive of Metropolia with limited access.
ENTRANCE EXAMINATION DATA
- Entrance examination consists of 3 parts:
- Article-based multiple-choice test
- English language test
- Mathematical skills test
- All 3 parts are in Moodle platform.
Data are obtained by applicants themselves as they participate the entrance examination.
The personal data are obtained from the data subjects themselves and delivered to Metropolia by themselves or through Edunation as described above. 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) to conduct student selection.
Access to the personal data contained in the personal data register of entrance examination for degree program in nursing (Edunation applicants) 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 entrance examination for degree program in nursing (Edunation applicants) of Metropolia, personal data processing agreements in accordance with Article 28 of the GDPR have been concluded with the following cooperation partners:
CSC – IT Center for Science Ltd. as a service provider and Zoom online video conferencing tool (Funet Miitti/NORDUnet)
Zoom is a web conferencing tool (Funet Miitti / NORDUnet, service provider CSC Oy). Zoom web conferencing tool is used to communicate and transmit information within the entrance examination for degree program in nursing (Edunation applicants). Applicants sign into Zoom meeting, entrance exam is remotely supervised through Zoom and entrance exam interviews are conducted in Zoom. CSC's Funet Miitti (Zoom) 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).
Moodle -online learning platform
Moodle (the open-source learning platform) is used for collecting the entrance exams data, since the entrance examination for degree program in nursing (Edunation applicants) is carried out in Moodle platform. Personal Moodle ID is created and given personally by Metropolia staff to the applicant, in order to log in to Moodle. Moodle is an open source learning platform that does not require Metropolia to procure an external service provider.
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.
As a general rule, personal data contained in the personal data register of entrance examination for degree program in nursing (Edunation applicants) 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.
The personal data collected for the personal data register of entrance examination for degree program in nursing (Edunation applicants) of Metropolia and processed within is, 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 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)
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.
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)
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 for processing in the personal data register of entrance examination for degree program in nursing (Edunation applicants) 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 register of entrance examination for degree program in nursing (Edunation applicants) of Metropolia University of Applied Sciences is based on voluntary registration and it is used to carry out the student selection for degree program in nursing (Edunation applicants).
- The personal data has been obtained from the data subjects themselves regarding the application to higher education and participation in the entrance examination and delivered to Metropolia through Edunation.
The personal data register of entrance examination for degree program in nursing (Edunation applicants) of Metropolia University of Applied Sciences and the data contained in it will not be used in automated decision-making or profiling.