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 Giosg.com Chat Service
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: Tapio Rimpioja
Position: Manager of Student Affairs, Student Affairs
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: tapio.rimpioja [at] metropolia.fi (tapio[dot]rimpioja[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Sini Vilpas
Position: Specialist, Student Affairs
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: sini.vilpas [at] metropolia.fi (sini[dot]vilpas[at]metropolia[dot]fi)
Contact details for questions regarding the purpose of the register, email: hakijapalvelut [at] metropolia.fi (hakijapalvelut[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 Metropolia’s Giosg.com Chat Service is to offer the students of Metropolia, people applying to study at Metropolia and people otherwise interested in Metropolia’s activities a modern service channel through which they can pose questions related to the areas of responsibility of the Student and Admission Services. The Personal Data Register of Metropolia’s Giosg.com Chat Service is used to process questions of a general nature asked by persons contacting Metropolia. The chat service is not intended for processing sensitive personal data or providing answers from Metropolia to sensitive issues. In such instances, the customer may be requested to contact Metropolia’s Student and Admission Services in person at one of its offices.
In Metropolia’s Giosg.com chat service, answers may be provided to the following types of questions, for example:
- what kind of education does Metropolia offer?
- when are Metropolia’s application periods?
- how many study places are on offer in a certain degree programme?
- how to apply for further studies, including the assessment of eligibility to apply
- questions related to student financial aid or other social benefits
Since the data controller, Metropolia, is obliged to perform a strong identification of its students every time they ask questions related to their personal study performance, the monitoring of their progress in studies or any sensitive subject, Metropolia can for the time being only provide answers to such queries after the identity of the inquirer has been verified and using the method of responding that is appropriate to the query. In other words, in matters such as these, no reply can be given to the inquirer because there is no way of verifying the inquirer’s identity.
Lawful basis for the processing of personal data:
The personal data contained in Metropolia’s Giosg.com chat service are processed under the following lawful bases:
- legal obligation (Universities of Applied Sciences Act, 932/2014)
Metropolia University of Applied Sciences has a legal obligation to provide UAS level education leading to a degree as well as support functions for education, such as an advisory service for matters related to the students and to applying to become a student. Metropolia University of Applied Sciences also has an obligation to identify its students as well as persons applying to become students at the UAS and participating in entrance examinations. Personal data are processed in the support functions for education and nearly all teaching activities.
- consent
The purpose of the Giosg.com chat service, which has operated on Metropolia’s public website since autumn 2019, is to offer Metropolia’s students, people applying to study at Metropolia and people otherwise interested in Metropolia’s activities a modern service channel for providing student affairs services. A person contacting the service may ask questions and receive replies concerning the educational offering and support activities for education provided by Metropolia in the form of chat messages. The chat service may only be used to process and give replies to questions of a general nature concerning Metropolia that do not require strong identification. Various data describing the online behaviour of the online visitor are saved in Metropolia’s Giosg.com chat service. Before the collection of online behaviour data can begin, the online visitor will be asked for express consent for this and for saving cookie data.
The lawful basis for the processing of the personal data in the Personal Data Register of Metropolia’s Giosg.com Chat Service is not “legitimate interest”. Therefore this section does not apply.
The data subjects of the Personal Data Register of Metropolia’s Giosg.com Chat Service are the users of the chat service.
The following personal data are stored in the Personal Data Register of Metropolia’s Giosg.com Chat Service:
Various data describing the online behaviour of the online visitor are saved in the chat service. Before the collection of online behaviour data can begin, the online visitor will be asked for express consent for this and for saving cookie data.
Online behaviour data/online analytics data (for each online visitor):
● customer-specific cookie ID (based on which the visitor to the web page can be identified)
● IP address
● web pages (URLs) visited
● web page (URL) from which the visitor has navigated to Metropolia’s public website
● time stamp
● operating system
● device
● browser
The data collected on the user of the chat service (i.e. online behaviour data):
The use of Metropolia’s chat service does not in itself oblige the user of the service to provide any personal data. In any case, the following data are collected on the users of Metropolia’s chat service (as they are collected on all visitors to Metropolia’s website regardless of whether they use the chat service or not):
● customer-specific cookie ID (based on which the visitor to the web page can be identified)
● IP address
● web pages (URLs) visited
● web page (URL) from which the visitor has navigated to the chat service on Metropolia’s public website
● time stamp
● operating system
● device
● browser
Data related to the chat service:
● content of the conversation in the chat service
● chat operator data
● online behaviour data related to the conversation in the chat service
● blacklisted users (blocked online visitors who are identifiable through a cookie or IP address)
● history information on communications through the chat service
Possible personal data provided by the user of the chat service during the course of the conversations:
The use of Metropolia’s Giosg.com chat service does not in itself oblige the user of the service to provide any personal data. The following data provided in Metropolia’s chat service by the user may be stored:
● Basic information: forename, surname
● Education and degree information: information about previous degrees completed, training undertaken, qualifications etc.
The personal data are obtained from the data subjects themselves.
Access to the personal data contained in the Personal Data Register of Metropolia’s Giosg.com Chat Service 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.
Personal data processing agreements in accordance with Article 28 of the GDPR have been or will be concluded with the following system providers and service providers:
Giosg.com Oy; chat service tool
Using the chat service tool, Metropolia offers its students, people applying to study at Metropolia and people otherwise interested in Metropolia’s activities a modern service channel through which it can offer them information on studies and education support services at Metropolia.
Microsoft Corporation (part of the O365 package); Metropolia’s email system
The email system is based on Microsoft O365, but it is operated on Metropolia’s own server. Service requests received through the chat service may be further processed and replies to them may be provided using Metropolia’s email system.
Leijonaverkot Oy (part of the Erillisverkot Group, formerly Deltagon Group Oy) and secure mail (Deltagon’s sec@gw secure mail solution)
The email encryption solution used on Metropolia’s own server, namely the Deltagon sec@gw secure mail solution, may be used for the transmission of sensitive personal data and confidential documents from email addresses outside Metropolia (for instance, when email is sent by a person planning to study at Metropolia from an email address that does not have the “@metropolia.fi” domain, or when a message is sent from Metropolia to such an email address).
Liana Technologies Oy; Liana®Cloud newsletter tool (e.g. sending of newsletters)
Newsletters are sent by email, if the data subject has given their written consent for this purpose, through the sending system of the Liana®Cloud newsletter tool.
Personal data contained in the Personal Data Register of Metropolia’s Giosg.com Chat Service will not, as a general rule, be transferred outside the EU or EEA or to international organisations.
The personal data contained in the register may be transferred outside the EU or EEA for the provision of IT services that are necessary for working or completing studies, based on a case-by-case consideration. The state to which personal data are transferred is the United States. It is also possible that personal data may be transferred to, for example, India, a country where global ICT service providers frequently base their help desk operations or ICT user support functions.
The international transfer of personal data from a personal data register of Metropolia University of Applied Sciences to the United States and/or elsewhere outside the EU or EEA is secured primarily with measures, i.e. Standard Contractual Clauses, provided for in Chapter V, Article 46 of the EU’s General Data Protection Regulation (GDPR). The Standard Contractual Clauses are included in agreements with ICT service providers concerning the processing of personal data.
Only the necessary data are transferred and the transfer is carried out in accordance with data protection legislation and within the restrictions placed by it. A separate agreement is always concluded on data security during the transfer.
In addition, it should be noted that a personal data processing agreement has been drawn up between Metropolia and Giosg.com Oy. This framework agreement permits the international transfer of personal data only within the EU or EEA, i.e. within the area subject to the GDPR.
All personal data collected and processed in the Personal Data Register of Metropolia’s Giosg.com Chat Service are, as a general rule, stored in the register for a period of five years. After this period, the data are erased. The retention period of five years is based on the retention time for customer data set by the provider of the chat service, Giosg.com (for more information, see Giosg.Com Oy’s privacy policy concerning the processing of customer data and the related retention times on the company’s website).
Service requests received through Metropolia’s Giosg.com chat service may be further processed by Metropolia’s Student and Admission Services and replies to them may be provided using Metropolia’s email system. In such a case, the processing and retention of personal data is subject to Metropolia’s archiving plan and the decision of the National Archives of Finland concerning the permanent storage of data held in the data systems of universities of applied sciences exclusively in an electronic format (see the decision of the National Archives of Finland concerning universities of applied sciences, issued 12 September 2017, registration no. AL/20757/07.01.01.03.02/2016 (in Finnish)).
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 (tuulia[dot]aarnio[at]metropolia[dot]fi), tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)).
Metropolia’s Data Protection Officer will respond to information requests 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 that their personal data are correct (right to rectify personal data), in which case processing will be restricted until the data controller can ascertain that the data are correct;
- processing is unlawful 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 for 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)
Partially applicable. Article 20 of the General Data Protection Regulation introduces a new right of the data subject: the right to receive their personal data in a “structured, commonly used and machine-readable format” and the right to transmit those data to another controller. The purpose of this right is to increase the opportunities available to data subjects to influence their personal data because this facilitates the transfer or copying of personal data from one data system environment to another (to their own systems, the opportunity to save the data for their personal use or to begin storing their personal data in systems controlled by reliable third parties). In this respect, the right to data portability from one system to another complements the right of access to one’s personal data.
The right to data portability from one system to another under Article 20 of the General Data Protection Regulation also means that the data subjects have the right to receive their personal data in a structured, commonly used and machine-readable format so that they can easily transfer those data from one system to another system with another controller. The data may be transferred at the data subject’s request directly from one data controller to another if this is technically feasible (section 2 of Article 20). Data controllers are encouraged to develop compatible formats that enable the transfer of data from one system to another, although data controllers are not obliged to accept or maintain data processing systems that are technically compatible.
It should be noted with respect to Article 20 of the General Data Protection Regulation that the right to data portability only applies to personal data processing activities that are based on:
- consent of the data subject (in accordance with Article 6(1)(a) or Article 9(2)(a) if the processing concerns special groups of personal data), or
- a contract to which the data subject is a party (in accordance with Article 6(1)(b)).
In other words, Article 20 of the General Data Protection Regulation must be complied with if the lawful basis for the processing of personal data is the consent of the data subject or the execution of a contract. The right only applies to personal data provided by the data subject to the data controller.
A request based on Article 20 of the General Data Protection Regulation 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 the processing of personal data concerning them which is based on Article 6(1)(e) (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.
Such a request to stop the processing of collected 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 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
FI-00530 Helsinki, Finland
Postal address: PO Box 800
FI-00531 Helsinki, Finland
Telephone (switchboard): +358 29 56 66700
Registry Office: +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 in a personal data register of Metropolia is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data. An account has been given for each register regarding how the personal data were obtained.
- The Personal Data Register of Metropolia’s Giosg.com Chat Service is based on voluntary participation and it is used to advise and guide users on the activities of Metropolia University of Applied Sciences Ltd and on studying at the UAS.
- No one is obliged to use the Giosg.com chat service on Metropolia’s public website, or to give their consent as a requirement to use the chat service.
- The personal data stored in the register have mostly been collected from the data subjects themselves. In some cases, data are obtained on the online visitor’s online behaviour using a web analytics functionality (after informing the data subject and obtaining their express consent for this).
The personal data contained in the Personal Data Register of Metropolia’s Giosg.com Chat Service are not used for automated decision-making or profiling.