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 Metropolia’s Bit1 Student Game Competition
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
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
Email: kirjaamo [at] metropolia.fi (kirjaamo[at]metropolia[dot]fi)
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 Metropolia’s Bit1 Student Game Competition is to manage the information needed to organise events and manage partner, student, customer, and visitor information.
Bit1 student game competition gives students an opportunity to showcase their game projects and compete for the title of the Student Game of the Year. It is operated by Metropolia University of Applied Sciences.
The purpose of processing personal data of the data subjects registered in the project register of Bit1 are:
- organising the Bit1 and PreBit events, and collecting and processing information necessary for their purposes
- processing activities in relation to communication and information activities of Bit1 and PreBits
- managing the contact information of the external co-operation partners (enterprises and organizations and their contact persons) of Metropolia
- collecting feedback and survey information in relation to the activities performed by Bit1 and PreBits
- understanding the background and behaviour of Bit1 website visitors
The controller processes the information in house, as well as subcontracts parties to process the data on the controller’s behalf.
Legal basis for the processing of personal data:
The processing of the personal data contained in the Bit1 register is partly based on the consent obtained directly from the data subject as they have given consent to the processing of their personal data for one or more specific purposes. This basis is relevant to Bit1 participants, jury members, and Bit1 organisers.
The processing of the personal data contained in the Bit1 register is partly based on the processing necessary for the performance of an agreement or contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into an agreement or contract. This basis is relevant in the case of partner contracts, co-operation contracts etc.
Consent is used as the legal basis for the processing of special categories of personal data contained in the register as well as the processing of sensitive personal data, such as biometric data (e.g. facial photos, video material collected from the events etc. in which persons are identifiable). This basis is relevant for anyone participating Bit1 events.
Not applicable in this register.
The data subjects in Bit1 register are consented participants of Bit1 and PreBit events, organisers of PreBits, partners of Prebits and Bit1, corporate partners of PreBits and Bit1, and event and website visitors.
In general, the personal data contained in the Bit1 register may include, among others, the first name and surname and possible contact details of a data subject who has agreed to be a part of the events, as well as other data recorded for the events.
Registration details entered personally by the data subject may include the following, among others: email, telephone number, address, date of birth, billing details and dietary requirements.
The following personal data is stored in the personal data register of Bit1:
BASIC INFORMATION AND CONTACT DETAILS
- forename; surname;
- address; postal code; city;
- telephone number; email address
- name of the team; name of the game
- associated organizations
- the PreBit and Bit1 events the person will be attending
- information about the game
CONSENT FOR AND INFORMATION ON CERTAIN ACTIONS
consent for receiving email related to the Bit1 and PreBit activities
- participant’s forename; surname;
- information in relation to related event activity and/or meeting, time and place
INFORMATION IN RELATION TO A SURVEY ORGANIZED BY BIT1
- forename and surname of a data subject giving feedback
- information in relation to the content/answers given and submitted for a survey organized by Bit1, time and place
PHOTOGRAPHS AND VIDEO MATERIAL
- volunteers may be photographed or (video)filmed during Bit1 and PreBit events
- the data subjects will be informed and asked to consent photographing or video filming prior to photographing or video filming activity
Information in relation to performing activities with collaborators, partners, financiers of Bit1:
BASIC INFORMATION AND CONTACT DETAILS
- collaborators’/ partners’ name/organization; name of the contact person of the collaborator/partner; email address of the contact person; title of the contact person within organization
ANALYTIC DATA OF WEBSITE VISITORS
- Analytical data, e.g., number of visitors; location (country); browser type; time spent on site and pages visited; source of visit. For more information, visit https://www.google.com/analytics/learn/privacy.html. To opt out, install Google’s browser add-on: https://tools.google.com/dlpage/gaoptout .
The personal data are obtained from the data subjects themselves.
Additionally, the controller collects personal data related to the purpose of use of the personal data register, generated as part of the controller’s operations. Within the bounds of applicable legislation, personal data are collected from sources in the public domain, as well as from other third parties, such as companies in the same group and other contractual partners.
Access to the personal data contained in Bit1 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 Bit1 register Data Processing Agreements in accordance with Article 28 of the GDPR will be concluded by Metropolia with the following cooperation partners:
Eventbrite event management system
The enrolment process for the events may be organized by using Eventbrite event management system.
G Suite for Education
The personal data processed within Metropolia's Bit1 register is being managed by Google's so-called G Suite for Education toolkit included in the educational application package. Personal and contact information, tables and feedback information from the data subjects is being processed by Google Drive cloud storage tool. Also, other Google-based tools are being used to process images, videos and research survey answers received from Bit1’s data subjects.
Metropolia’s email system (Microsoft Office 365)
The employees of Metropolia’s Bit1 are using Metropolia’s email system manage and organize work tasks. Although Metropolia has procured the email system as part of the Microsoft Office 365 Education service package, the system is operated on Metropolia’s own server.
Microsoft TEAMS (Microsoft Office 365 Education)
The employees of Metropolia’s Bit1 are using Microsoft Teams for internal communication within Bit1 and other Metropolia actors. Microsoft Teams has been procured to Metropolia as part of Microsoft Office 365 educational application package. Also, other Microsoft -based tools are being used to process information within the tasks and work assignments of the Bit1.
Zoom
Bit1’s online events are organised using the Zoom video conference tool.
Dynasty case and contract management system
Contracts relating to Metropolia’s Bit1 are managed through the Dynasty case and contract management system.
Reportronic and Halli project management systems
Reportronic and Halli project management systems are used for processing data about the activities of Bit1.
Wordpress –web pages
Public webpages of Bit1 are constructed and published by using Wordpress tool kit. Bit1’s web pages are operated on Metropolia’s own server. The Bit1’s employees contact information is being published in the Bit1’s web pages. Personal information of Bit1 and PreBit participants and jury is published on the webpages with their express consent.
Google Analytic tools
Public webpages of Bit1 use Google Analytics to analyse our visitor data. For more information, visit https://www.google.com/analytics/learn/privacy.html. To opt out, install Google’s browser add-on: https://tools.google.com/dlpage/gaoptout .
Personal data from Bit1’s register is not habitually transferred outside the EU or EEA, nor processed outside the EU or EEA, unless this is necessary for the technical implementation of the processing (for example if the technical maintenance of systems is located outside the EU or EEA), or in order to manage international functions related to the purpose of use of the project register.
In transferring personal data, the controller complies with the standard contractual clauses approved by the European Commission in relation to the transfer of personal data to third-party countries, or alternatively implements other appropriate safeguards, or alternatively ensures that the third-party country can guarantee a sufficient level of data protection.
When the data collection is based on consent, the personal data collected for and processed within Bit1 register will be immediately removed upon request. When data collection is based on a contract, such as an employment contract or a collaboration contract, the data will be stored for as long as the contract stands.
The controller of the data file regularly evaluates the need for storing data in accordance with its internal practices. The personal information in the project register is only stored for as long as and to the extent that each category of data is needed, proportionate to the purpose of processing of the personal data.
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.
A data subject may submit a data request by providing Metropolia with a carefully completed, printed, and personally signed data subject request form, available on Metropolia's public website and/or intranet. The form can be submitted either electronically to tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi) or in person at Metropolia's Myllypuro campus. If printing is not possible, provide similar information as requested in the form to tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi). You may be asked to verify your identity so that we can respond to the data request safely.
Metropolia's Myllypuro Campus
Myllypurontie 1, 00920 Helsinki
The response to a data subject request will be provided by Metropolia's Data Protection Officer. For additional information about the processing progress or the content of the response, the Data Protection Officer may be contacted.
According to the GDPR, the data controller must respond to a data subject's request to exercise their rights within one month of receiving the request.
Data subjects can submit requests regarding the following topics:
Right to Access Personal Data
The data subject has the right to obtain confirmation from the data controller on whether their personal data is being processed. They are also entitled to inspect the personal data stored about them in the register and receive copies of the data.
Right to Rectification and Restriction of Processing
The data subject has the right to request the controller to restrict processing in any of the following situations:
- The data subject disputes the accuracy of their personal data (right to rectification), in which case processing is restricted for the period needed to verify the accuracy of the data.
- The processing is unlawful, and the data subject opposes the deletion of their personal data and instead requests the restriction of its use.
- The data controller no longer needs the personal data for processing purposes, but the data subject requires it for establishing, exercising, or defending legal claims.
Right to Erasure
The data subject has the right to have their personal data erased from Metropolia's register without undue delay, provided one of the following applies:
- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- The data subject withdraws consent on which the processing is based, and there is no other legal basis for processing.
- The personal data has been unlawfully processed.
- The personal data must be erased to comply with a legal obligation under EU law or national legislation.
- Right to Data Portability
Not applicable.
Right Not to Be Subject to a Personal Data Security Breach
The data subject has the right not to be subjected to a personal data breach, as defined in GDPR Article 33, due to negligence by the data controller or the processor handling personal data on behalf of the controller. The data subject has the right to be informed without undue delay if a personal data breach is likely to result in a high risk to their rights and freedoms.
According to Article 21 of the EU’s General Data Protection Regulation, the data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) of Article 6(1) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), such as profiling based on these provisions. The data controller may no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
The request to stop processing of collected personal data can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity when submitting the request.
According to Article 21 of the EU’s General Data Protection Regulation, the data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) of Article 6(1) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), such as profiling based on these provisions. The data controller may no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
The request to stop processing of collected personal data can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity when submitting the request.
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.
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)
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
Registry: +358 29 566 6768
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:
- 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 activities of the project register of the Bit1, 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 explanation has been given for each register regarding how the personal information was obtained.
Personal data of the data subjects registered in the project register of the Bit1 is based on voluntary registration and it is used to manage the activities and services of the Bit1.
It is not compulsory to be registered in the personal data register of Bit1.
The personal data stored in the project register have mainly been collected from the data subjects themselves. However, the controller collects personal data related to the purpose of use of the personal data register, generated as part of the controller’s operations. Within the bounds of applicable legislation, personal data is collected from sources in the public domain, as well as from other third parties, such as companies in the same group and other contractual partners.
Volunteers may be photographed or (video)filmed during events, workshops and educational activities organized by Bit1. The data subjects will be informed and asked to consent to photographing or video filming prior to photographing or video filming activity.
The data register of Bit1 of Metropolia University of Applied Sciences and the data contained in it will not be used in automated decision-making or profiling.