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 Student Wellbeing Services
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: Maarika Kortelainen
Position: Student Wellbeing Advisor, Student Wellbeing Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: maarika.kortelainen [at] metropolia.fi (maarika[dot]kortelainen[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Person responsible for the content of the register:
Name: Maarika Kortelainen
Position: Student Wellbeing Advisor, Student Wellbeing Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: maarika.kortelainen [at] metropolia.fi (maarika[dot]kortelainen[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 aim of Metropolia’s Student Wellbeing Services is to support and promote the holistic wellbeing of the students as well as their ability to study, taking the students’ needs and personal circumstances into consideration. The focus of the activities is on preventive action, which is interactive and outwardly directed. The basic task of the Student Wellbeing Services is to offer students support, advice and guidance in their studies and in the maintenance of their wellbeing, as well as removing any obstacles to their wellbeing. Activities are organised on three levels: Personal support for students, working in small groups, networks and workshops, and broad collaboration within and outside Metropolia.
At Metropolia, student wellbeing is promoted by offering and developing forms of activity for the students to support the maintenance of wellbeing, safety and studying ability and prevent existing problems from becoming exacerbated.
The purpose of processing of the Personal Data Register of Metropolia’s Student Wellbeing Services is to enable the processing of personal data in connection with the provision of Metropolia’s Student Wellbeing Services. The Student Wellbeing Services may process the notes created in a meeting with a student with the student’s consent. In addition, the Personal Data Register of Metropolia’s Student Wellbeing Services includes the processing of consents given by the data subjects. Conversations between the students and the employees of the Student Wellbeing Services and the notes prepared with the students’ consent are confidential.
Lawful basis for the processing of personal data:
The processing of the personal data included in the Personal Data Register of Metropolia’s Student Wellbeing Services is based on the consent of the data subjects.
Consent is also used as the lawful basis for the processing of special categories of personal data contained in the register, including the processing of sensitive personal data (data relating to health), which are listed as data requiring special protection in Article 9 of the EU’s General Data Protection Regulation.
To support the work, the student is asked, in writing on a consent document, for specific, informed, freely given and provable consent for the processing of their personal data in the activities of Metropolia’s Student Wellbeing Services.
In addition, the processing of the personal data is based partially on the legal obligation to provide student health care for students in higher education, which Metropolia’s Student Wellbeing Services provides (Act on student health care for students in higher education, 695/2019).
The lawful basis for the processing of personal data in the Personal Data Register of Metropolia’s Student Wellbeing Services is not ‘legitimate interest’. Therefore this section does not apply.
The data subjects of the Personal Data Register of Metropolia’s Student Wellbeing Services are the students who use the student wellbeing services.
The following data may be recorded in this register:
Consent document:
- data subject’s forename, surname, signature and name in block letters
The Student Wellbeing Services may record notes with the student’s consent. The notes may include the following information:
- person’s name (efforts will be made to replace this with, for example, numerical IDs or to modify it so that the person is no longer identifiable without additional information);
- degree programme;
- the reason for the contact reported by the student, the main points of the conversation held and the further measures agreed on.
At the student’s request, the Student Wellbeing Services may prepare written summaries of the notes taken in its meetings, and the student may provide these summaries to the authorities or other third parties. In addition, the notes are used when working with the student. The student may forbid Metropolia’s Student Wellbeing Services from taking notes.
When taking notes, efforts will be made to modify the personal data so that the person whom they concern is no longer identifiable without additional information.
The personal data are obtained from the data subjects themselves through their contact with Metropolia’s Student Wellbeing Services or in a meeting with the student.
Digital and paper notes
The notes are not shared or otherwise disclosed to third parties and they are stored in locked, data secure cabinets or on protected network drives to prevent outsiders from accessing them. At the student’s request, written summaries of the notes may be prepared, and the student may provide these summaries to the authorities or other third parties. The student will personally decide whether they wish to disclose a document.
Microsoft Corporation and Microsoft Teams
The Microsoft Teams online videoconferencing tool is used for holding the meetings of Metropolia’s Student Wellbeing Services through a remote connection due to the coronavirus situation. A personal data processing agreement has been concluded with Microsoft Corporation in accordance with Article 28 of the GDPR. Access to the personal data in the system will be given when necessary (using administrator rights; for example, when a technical fault needs to be repaired, access is given 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.
As a general rule, personal data contained in the personal data register of the xx activities / project of Metropolia will not be transferred outside the EU or EEA or to international organisations.
However, personal data contained in the personal data register may be transferred outside the EU or the EEA in order to provide IT services necessary for work or study, on a case-by-case basis. The destination country to which the personal data is transferred then, is mainly the United States. It is also possible that India is the destination country as global ICT service providers use often India as a host country for the international helpdesk service / ICT technical user support. International transfers of personal data from the Metropolia University of Applied Sciences' personal register to the United States and / or elsewhere outside the EU / EEA are primarily secured then by the safeguard provided for in Article 46 of Chapter V of the EU General Data Protection Regulation (GDPR), standard contractual clauses. The SCC (Standard Contractual Clauses) clauses will be included as part of the personal data processing agreement to be drawn up with the ICT service provider. Only the necessary data will be transferred and the transfer will be made in accordance with and within the limits set by data protection law. The security and data protection of the transfer are always agreed separately.
(-> If you use IT systems, softwares etc. provided by IT service provider registered in United States /outside the EU/EAA, it might be possible that the IT service provider uses servers for the data storage located in United States /outside the EU/EEA -> This might mean that personal data will be transferred to United States/ outside the EU/EEA as the storing of personal data is considered as processing of personal data according to the GDPR, and as storing personal data into the data storage servers located outside the EU/EEA, is considered as transferring personal data outside the EU/EEA according to the GDPR).
If that is the case, you need to specify to which third countries outside the EU or EEA you are transferring personal data (list of countries/mapping of countries).
When mapping transfers, do not forget to also take into account onward transfers, for instance whether your processors outside the EEA transfer the personal data you entrusted to them to a sub-processor in another third country or in the same third country. In other words, you must know where the personal data you exported may be located or processed by the importers (map of destinations).
Keep in mind that remote access from a third country (for example in support situations) and/or storage in a cloud situated outside the EEA, is also considered to be a transfer. More specifically, if you are using an international cloud infrastructure you must assess if your data will be transferred to third countries and where, unless the cloud provider clearly states in its contract that the data will not be processed at all in third countries.
As a next step, you must identify the transfer tools (safeguards) you are relying on amongst those described in the Chapter V of the GDPR (Articles 45 - 49).
Article 46 of the Chapter V of the GDPR lists standard contractual clauses (SCCs) as a transfer tool containing “appropriate safeguards” for the data transfer.
Whatever GDPR transfer tool you choose, you must ensure that, overall, the transferred personal data will have the benefit of an essentially equivalent level of protection. “An essentially equivalent level of protection” means that the transferred personal data is afforded a level of protection in the third country that is essentially equivalent to that are guaranteed in the EEA where strict data protection legislation prevails.
It might be useful to contact Data Protection Officer of Metropolia UAS (dpo [at] metropolia.fi (dpo[at]metropolia[dot]fi); tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)) in a case considering international personal data transfers outside the EU or EEA.
The data in the Personal Data Register of Metropolia’s Student Wellbeing Services that have been recorded in notes are stored in data secure, locked cabinets or on protected network drives, and the notes are destroyed or erased in a data secure manner after five years have passed from the last meeting of the student with the Student Wellbeing Services. However, the student is entitled to request that the retention period for the notes be extended by a total of four (4) years, a period that covers the normal duration of the right to study.
In addition, any other personal data collected from the data subjects with their consent in the activities of Metropolia’s Student Wellbeing Services are only stored for as long as is necessary for the processing of these data. Metropolia’s Student Wellbeing Services are responsible for destroying or erasing their notes and the personal data they process in the course of their activities in a data secure manner.
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.
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)
General description of the technical and organisational security measures aiming at protecting the personal data of the data subjects and the personal data registers:
- The protection of the register has been agreed upon with the system providers. If necessary, the responsibilities have been described in adequate detail in the appropriate agreements.
- The employees and other personnel have undertaken to comply with the obligation of secrecy and to keep confidential the information they receive in connection with the personal data processing.
- The system providers (personal data processors) undertake to maintain the register and the personal data relating to it in accordance with good data processing practices and comply with the obligation to absolute secrecy and confidentiality.
- The data security of the personal data register of the data controllers and the confidentiality of the data contained therein are ensured with appropriate technical and administrative means in accordance with good data processing practices.
- The data controllers have restricted user rights and authorisations to data systems, tools and other storage platforms in such a way that they can only be accessed and processed by the persons who are necessary for such processing due to their job duties or position.
- The system containing personal data may only be used by employees who are entitled to process personal data due to their job duties and/or position. Such employees will be given the appropriate training for their duties.
- Every user of a tool/system must identify themselves with their personal codes, which are issued when the right to access the tool/system is granted. The right of access will expire once the employee resigns or is transferred from the duties for which they were granted the right at Metropolia.
- The data are collected in databases that are protected logically and physically.
The databases and their back-up copies are located in locked premises, and the data can only be accessed by certain pre-appointed persons.
Information on whether the provision of personal data for processing in the Personal Data Register of Metropolia’s Student Wellbeing Services 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 Student Wellbeing Services is a personal data register based on voluntary participation and is used to process the personal data of the students in the activities of Metropolia’s Student Wellbeing Services with the students’ consent.
No one is obliged to join this personal data register.
The personal data stored in the register have been collected from the data subjects themselves.
The personal data in the Personal Data Register of Metropolia’s Student Wellbeing Services are not used for automated individual decision-making or profiling.