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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.

Submitted on 19.5.2020 - 11:25

Name of the register

Personal Data Register of Metropolia Event Management

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

Persons responsible for the content of the register:

Name: Tarmo Pallari
Position: Head of department/Head of degree programme/Supervisor
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: tarmo.pallari [at] metropolia.fi

Name: Taru Ruotsalainen
Position: Head of Continuing Education
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: taru.ruotsalainen [at] metropolia.fi

Contact details of the contact persons for the register:

Name: Petra Heino
Position: Study Coordinator, Continuing Education and Enterprise Services
Address: Metropolia University of Applied Sciences, PO BOX 4000, 00079 Metropolia
E-mail: petra.heino [at] metropolia.fi

Name: Olga Trishkina
Position: Assistant, Continuing Education
Address: Metropolia University of Applied Sciences, PO BOX 4000, 00079 Metropolia
E-mail: olga.trishkina [at] metropolia.fi

Contact details in questions concerning the purpose of the register:

e-mail: yrityspalvelut [at] metropolia.fi and/or jatkuvaoppiminen [at] metropolia.fi

Data Protection Officer

Tuulia Aarnio, Metropolia’s Data Protection Officer
Tel: +358 40 844 0690
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 personal data register of Metropolia Event Management and the personal data it contains is to manage various registrations for events and education. 

Data is collected for the purposes of practical arrangements, such as

  • enrollment management,
  • training invitations,
  • registering the completion of courses,
  • invoicing,
  • gathering feedback,
  • distributing certificates,
  • informing event registrants about current issues in training and event management (eg. sending information about canceled training and/ or event to those who have registered via SMS).

The personal data register of Metropolia Continuing Education and Enterprise Services as well as continuous learning (other learning solutions) services and the privacy notice prepared for it supplements the privacy notice of the personal data register of Metropolia Event Management. The privacy notices can be viewed via the Privacy section of Metropolia's public website.

Legal basis for the processing of personal data:

Metropolia Event Management process the personal data in their register based on:

Consent

  • In the case of newsletters and marketing communications, the recipient gives consent to receive newsletters and marketing communications

Agreement

  • Operations related to client relations and partnerships are in some cases based on agreements (contracts), when the legal basis relies on the agreement.
  • For example, a) a commitment agreement (sitouttamissopimus) between the employing company and the employee taking part in the training activities:
    • Using a commitment agreement, the employee can authorize their employer to monitor the progress of the supplementary training funded by the employer. With this agreement, the employee gives their written consent for the employing company to monitor the progress of their studies in cooperation with the organizer of the training activities (Metropolia) by allowing the company to receive updates from Metropolia regarding which parts of the training the employee has completed. However, the employing company does not have the right to access the grades or written personal assessment of the employee (registered);
  • In other cases b) an agreement between the employing company and Metropolia regarding the purchase of education/training from Metropolia.

Legitimate interests

  • The personal data register of Metropolia Event Management process the personal data in their register partly based on legitimate interests regarding Metropolia’s operations as an organization selling event and education services. Part of the client relations operations of the personal data register of Metropolia Event Management are based on this (implementation of event communications, client relations management). The information of those registered in the personal data register of Metropolia Event Management is not used for direct marketing in case the person has not given their specific consent to receive direct marketing.

Legal obligation

  • The processing of information in the personal data register is based on a legal obligation to keep a register of study credits completed through the training activities
    • Universities of Applied Sciences Act (932/2014)
    • Act on the National Registers of Education Records, Qualifications and Degrees (884/2017)

The study records are kept permanently in the case of educational/training activities for which Metropolia awards study credit to the participant. These permanent study credit records are registered in Metropolia’s OMA/Peppi student information system (forming part of Metropolia’s student register).

Legitimate interests of the data controller or a third party

The personal data register of Metropolia Event Management process the personal data in their register partly based on legitimate interests regarding Metropolia’s operations as an organization selling event and education services. Part of the client relations operations are based on this (marketing related to business endeavors, client relations management, implementation of event communications).

Data recipients or recipient groups and regular disclosures

The client data of the personal data register of Metropolia Event Management is administrated through Metropolia’s client relations management (CRM) system. The CRM system contains information on client roles, sent offers, agreements, commissions as well as client meetings and cooperation.

The personal data register of Metropolia Event Management contains the following personal information (presented in groups):

Basic information of the participants:

  • first name; last name; social security number; address; e-mail; telephone number;
  • dietary requirements;
  • educational background; job title/responsibilities;
  • if the employer funds the activities, Metropolia collects the employing company’s/organisation’s information
    • name
    • VAT number
    • billing information
    • address and possible reference for invoicing
  • consent for direct marketing

Educational information of the participants:

  • past participation in educational/training activities
  • timings of the previous educational/training activities
  • funded/commissioned by which company/organization
  • “expectations for the training activities” information before participation
  • where the participant received information on the educational/training activity
  • did the provider of the educational/training activities award study credits (yes/no)
  • did the participant complete the educational/training activities (yes/no)
  • possible qualification/certification received from the educational/training activities (for example, the hygiene passport)
  • information on the grade

Basic information of those participating in tailor-made training solutions or other services:

  • first name; last name
  • e-mail
  • consent for direct marketing

Educational information of those participating in tailor-made training solutions or other services:

  • past participation in educational/training activities
  • timings of the previous educational/training activities
  • if funded/commissioned by a company/organization, did the provider of the educational/training activities award study credits (yes/no)
  • did the participant complete the educational/training activities (yes/no)
  • possible qualification/certification received from the educational/training activities (for example, the hygiene passport)
  • information on the grade

Information about the client role/other role in the CRM system:

  • client of which Metropolia service: business, RDI, education or alumni
  • whether the registered is the contact person for the invoicing of their employer and is therefore registered in the CRM system
  • whether the registered is the contact person for agreements, commissions, client meetings or other cooperation between their employer and Metropolia, and is therefore registered in the CRM system

In the case of company contact people, information on the procedures:

  • sent offers
  • agreements and commissions
  • client meetings
  • other cooperation

Logged information related to Metropolia’s use of the CRM system:

Using the CRM system automatically creates log entries. These are utilized for the purposes of data security, technical development as well as observing, preventing and solving error situations, Information Society Code (917/2014) 138§, 141§, 144§, 272§. The logs are preserved for the duration required for these purposes and they are not used for any other purposes.

Additionally, it is worth mentioning that client relations managers have been assigned in the CRM system for clients and partners according to the client relations management model used in Metropolia. The assigned client relations managers are in charge of updating the client information. All CRM users are responsible for updating the contact information related to the companies they are in contact with. The CRM system allows a contact person to be deleted by making them passive, thus rendering the erasure of contact information unnecessary. After making the contact person passive, their information can no longer be modified or used together with other information.

Regular sources of personal data

The personal data has mainly been obtained from the registered individuals (data subjects) through enrollment procedures for educational/training activities.

In some cases the employing company purchasing educational/training activities from Metropolia may have forwarded a list of their employees to Metropolia and asked to enroll them as participants for an educational/training activity they are funding for their employees.

In these cases the employing company has often informed the participating employee about the educational/training activity funded for them and purchased from Metropolia. As an example, a commitment agreement or similar document may have been signed between the employing company and the registered participant, where the decision (to enroll the employee as a participant to educational/training activities organized by Metropolia) has been informed to the data subject.

With the commitment agreement the employee has been able to authorize their employer to monitor the progress of the educational/training activities funded by the employer. The employee has been able to give their written consent for the employing company to monitor the progress of their studies in cooperation with the organizer of the training activities (Metropolia) by allowing the company to receive updates from Metropolia regarding which parts of the training the employee has completed. However, the employing company does not have the right to access the grades or written personal assessment of the employee without a specified consent given by the employee to the employing company.

Information systems used in the processing of personal data

The data contained in the personal data register of Metropolia Event Management is processed using the various IT systems, applications and software procured by Metropolia.

Lyyti Event Management System

Participants enroll to the educational/training activities and events produced by Metropolia through the Lyyti event management system. In the case of activities that award study credits, the information can be transferred from Lyyti to the OMA/Peppi student register system.

Metropolia E-mail System (part of Microsoft O365, but the e-mail runs on Metropolia’s own server)
The e-mail system running on Metropolia’s own servers is utilized in managing the information in the personal data register of Metropolia Continuing Education and Enterprise Services, for example in situations related to client relations management.

Microsoft Dynamics CRM (O365) System

Information related to client relations management is saved into the CRM system directly, and part of the information is transferred through invoicing. External lecturers register their fee payment information through the e-form, from which the information is transferred into the fee payment system. From there the process moves on to payroll.

Description of the groups of data subjects and personal data groups

Access to the personal data contained in the personal data register of Metropolia Event Management 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, personal data processing agreements in accordance with Article 28 of the GDPR will be concluded with the following cooperation partners:

Lyyti Ltd and the Lyyti event management system

Participants enroll to the educational/training activities and events produced by Metropolia through the Lyyti event management system. In the case of activities that award study credits, the information can be transferred from Lyyti to the OMA/Peppi student register system.

Metropolia e-mail system (part of the Microsoft O365 package, but the e-mail runs on Metropolia’s own server)
The e-mail system running on Metropolia’s own servers is utilized in managing the information in the personal data register of Metropolia Event Management, for example in situations related to client relations management.

Microsoft Corporation and Microsoft Dynamics CRM (O365) system (Metropolia’s client relations management system CRM)
Information related to client relations management is saved into the CRM system directly, and part of the information is transferred through invoicing. External lecturers register their fee payment information through the e-form, from which the information is transferred into the fee payment system. From there the process moves on to payroll.

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

Personal data contained in the personal data register of Metropolia Event Management will not be transferred outside the EU or EEA or to international organisations.

Personal data retention times

The personal data collected for and processed within the personal data register of Metropolia Event Management is stored as follows:

  • Records of educational/training activities that award study credits are stored permanently. These permanently stored study credits are saved into Metropolia’s OMA/Peppi student register system (forming part of Metropolia’s student register).
  • Activities awarding study credits are addressed in the Act on the National Registers of Education Records, Qualifications and Degrees.

Other personal data collected by the personal data register of Metropolia Event Management is stored in the register for the duration of the client relationship, and two years after its end.

If the registered announces their wish to end their client relationship with Metropolia, the personal data of the data subject is erased immediately (excluding the aforementioned study credits, which are addressed in the Act on the National Registers of Education Records, Qualifications and Degrees and which are under the legal obligation for permanent retention).

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

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: tuulia.aarnio [at] metropolia.fi, 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)

Not applicable.

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, 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 e

Information on whether the provision of personal data for processing in the personal data register of Metropolia Event Management 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.

It is not compulsory to be registered in the personal data register of Metropolia Event Management. The data subject can easily make the erasure request to have their data removed from the register.

The personal data stored in the register has mostly been collected from the data subjects themselves.

In some cases the employing company has forwarded the information of their employee as a participant for an educational/training activity they are funding for their employees. However, in these cases the participant and their employee have informed each other about the situation, and they have often also drawn up a commitment agreement:

  • With the commitment agreement the employee has been able to authorize their employer to monitor the progress of the educational/training activities funded by the employer.
  • The employee has been able to give their written consent for the employing company to monitor the progress of their studies in cooperation with the organizer of the training activities (Metropolia) by allowing the company to receive updates from Metropolia regarding which parts of the training the employee has completed.
  • However, the employing company does not have the right to access the grades or written personal assessment of the employee.

Automated individual decision-making, including profiling

The personal data register of Metropolia Event Management and the data contained in it will not be used in automated decision-making or profiling.