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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 10.12.2020 - 15:10

Name of the register

Personal data register of SIMHE-Metropolia services

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

Person responsible for the content of the register:

Name: Heidi Stenberg
Position: Project Director
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: heidi.stenberg [at] metropolia.fi

Contact details of the contact person for the register:

Name: Outi Lemettinen
Position: Project Manager (SIMHE path, Deploying Competence in Finland)
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: outi.lemettinen [at] metropolia.fi

Contact details in questions concerning the purpose of the register:

simhe-info [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 personal data register of SIMHE-Metropolia services (Supporting Immigrants in Higher Education in Finland) contains data regarding applicants and students with immigrant-background who apply for SIMHE-Metropolia services to receive guidance and counselling and to study in degree programmes of SIMHE projects. Metropolia University of Applied Sciences offers SIMHE services for highly educated immigrants to recognize their competences and for guiding them to suitable educational and career paths.

The purpose of the personal data register of SIMHE-Metropolia services and the personal data it contains is to manage applicant information of people applying for SIMHE-Metropolia services to study and to receive guidance and to manage personal data and completed studies of students of SIMHE-Metropolia services.

Following privacy notices supplement the privacy notice of personal data register of SIMHE-Metropolia services:

 

Legal basis for the processing of personal data:

The processing of the personal data contained in the personal data register of SIMHE-Metropolia services is based mainly on the public interest and the exercise of official authority. In accordance with Universities of Applied Sciences Act (932/2014), the main mission of universities of applied sciences is to provide higher education.

In addition, processing of the personal data is based on consent obtained from the data subject. It is a matter of consent, when a person applies voluntarily for SIMHE services and takes part in a personal guidance discussion with a Metropolia expert of the field who asks for consent for taking notes.

Legitimate interests of the data controller or a third party

The legal basis for the processing of personal data contained in the personal data register of SIMHE-Metropolia services is not “legitimate interests”. Therefore this section does not apply.

Data recipients or recipient groups and regular disclosures

The data subjects in the personal data register of SIMHE-Metropolia services are people using the guidance and counselling services, people applying for SIMHE-Metropolia services and immigrants taking part in SIMHE-Metropolia services.

The following personal data is stored in the personal data register:

  • Basic information of applicants: forename(s), last name, personal identity code, gender, first language, nationality, address
  • Applicant’s previously completed studies and the previously acquired degree in higher education and documents related to those
  • Data concerning application to studies and grounds for admission for each applicant, to the extent necessary for their participation in the studies of the various SIMHE projects
  • Data concerning result of admission, receiving the right to study and registration to the educational institute
  • The applicant’s approval or denial of disclosure of their personal data for purposes of direct educational marketing
  • Data concerning work experience affecting professional choice and leisure activities of the applicant
  • Forwarding accident and damage reports of the students to the insurance company
  • Contact information of various cooperation partners collected in connection with SIMHE services (forename, last name, email, organization information)
  • Contact information of various cooperation partners collected in connection with event registration of SIMHE projects (forename, last name, email, phone number, title, organization information, dietary requirements)

Regular sources of personal data

The personal data is mostly obtained from the data subjects themselves. In additition, the personal data is obtained from:

  • ESF (European Social Fund) personal data form
  • Studyinfo.fi-service (Opintopolku.fi-service), maintained by the Finnish National Agency for Education, regarding the application to higher education
  • OILI service of annual enrolment, maintained by the Finnish National Agency for Education, regarding the information of student’s enrolment as attending or as non-attending
  • User management of Metropolia IT Services
  • The Population Register Centre

Information systems used in the processing of personal data

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

 

Studyinfo.fi-service (Opintopolku.fi-palvelu)

Studyinfo.fi -service, maintained by the Finnish National Agency for Education, regarding the application to higher education and the result of admission.

 

The OMA/Peppi Student Registry System

The personal data in the Metropolia Student and Study Information register regarding completed studies is processed in Metropolia’s OMA system, which contains a role-specific virtual dashboard structure. Participants of courses that award credits are entered into the OMA/Peppi system so they can receive a Metropolia username and so that their credits can be permanently saved into the student registry.

 

E-form software regarding management of student registry

E-form has been used for event registrations of Deploying Competences in Finland, SIMHEpath and SIMHE continuation projects and for participant search of SIMHEpath project. Regarding events, the e-form is replaced with Lyyti Event Management System. In addition, it is still possible to register for the customer register of SIMHE Guidance Services via the e-form, on the basis of which a newsletter addressed to customers is sent by e-mail.

 

Lyyti Event Management System

Lyyti is a web based event management system, which is used for events of various SIMHE projects and services. Personal data of participants is collected and information regarding the event is communicated via Lyyti. Lyyti system is also used for collecting and reporting feedback. Lyyti Event Management System is used in Deploying Competences in Finland and SIMHEpath projects, other SIMHE events and coordination of group and personal guidance.

 

VIRTA - the data warehouse for higher education

In the service, maintained by CSC - IT Center for Science, institutions of higher education keep partial copies of their student registers. VIRTA is the national data warehouse for higher education.

 

Liana®Cloud newsletter tool (communications about services and e.g. sending of invitations to events)

Marketing of SIMHE services and stakeholder communication related to SIMHE-Metropolia services is operated via Liana®Cloud newsletter.

 

SIMHE app

The application helps to recognize immigrants’ competences and supports their guidance. The updated version of the application will also include support for employment paths and non-degree related educational paths. Project takes place in 2019-2021.

 

Metropolia’s email system

Newsletters related to SIMHE-Metropolia services are sent by email through Metropolia’s Microsoft Outlook Exchange email system. Although Metropolia has procured the email system as part of the Microsoft O365 service package, the system is operated on Metropolia’s own server.

 

Security mail (Deltagon’s sec@gw -security mail solution)

Deltagon's sec@gw security e-mail solution can be used to forward sensitive personal data and confidential documents to e-mail addresses outside Metropolia (when e-mail is sent to a non-“@ metropolia.fi” e-mail address, or back to Metropolia).

Microsoft O365 Forms query tool and OneDrive

Microsoft Forms query tool is used for marketing of SIMHE services, stakeholder communication, customer communication and e.g. collecting feedback from projects. Microsoft OneDrive is used for providing guidance and counselling services and also for communication of project participants in Deploying Competences in Finland and SIMHEpath projects.

 

Google Forms query tool

Google Forms query tool is used for collecting feedback and other queries from projects.

 

Facebook

Facebook is also used for marketing of SIMHE services but personal data is not collected there.

 

Microsoft Teams web conferencing tool

Microsoft Teams is a web conferencing tool, which is used for remote steering In addition, Microsoft teams is used for communication with SIMHE partners and stakeholders.

 

Zoom web conferencing tool

Zoom is a web conferencing tool (Funet Miitti / NORDUnet, service provider CSC Oy). Zoom is a web conferencing tool, which is used for remote steering as well as communication with SIMHE partners and stakeholders. The Center for Science Information Technology - IT Center for Science - CSC's Funet Miitti (Zoom) service is used at Universities of Applied Sciences. The service has been implemented jointly in co-operation with NORDUnet and is therefore not part of the publicly available Zoom service. In addition, the Zoom service provided by NORDUnet operates entirely in the EU, in server environments reserved for NORDUnet's own use. These servers are located in Denmark and Sweden. The services have also been agreed with NORDUnet and Zoom, taking into account the requirements of European data protection regulations (GDPR).

 

Description of the groups of data subjects and personal data groups

Access to the personal data contained in the personal data register of SIMHE-Metropolia services 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 are /will be concluded with the following cooperation partners:

The Finnish National Agency for Education and Studyinfo.fi-service (Opintopolku.fi-palvelu)

Studyinfo.fi-service, maintained by the Finnish National Agency for Education, regarding the application to higher education and the result of admission.

Eduix Ltd and the e-form software

E-form has been used for event registrations of Deploying Competences in Finland, SIMHEpath and SIMHE continuation projects and for participant search of SIMHEpath project. Regarding events, the e-form is replaced with Lyyti Event Management System. In addition, it is still possible to register for the customer register of SIMHE Guidance Services via the e-form, on the basis of which a newsletter addressed to customers is sent by e-mail.

Lyyti Ltd and Lyyti Event Management System

Lyyti is a web based event management system, which is used for events of various SIMHE projects and services. Personal data of participants is collected and information regarding the event is communicated via Lyyti. Lyyti system is also used for collecting and reporting feedback. Lyyti Event Management System is used in Deploying Competences in Finland and SIMHEpath projects, other SIMHE events and coordination of group and personal guidance.

CSC - IT Center for Science and VIRTA – the data warehouse for higher education

In the service, maintained by CSC - IT Center for Science, institutions of higher education keep partial copies of their student registers. VIRTA is the national data warehouse for higher education.

Liana Technologies Ltd and Liana®Cloud newsletter tool (communications about services and e.g. sending of invitations to events)

Marketing of SIMHE services and stakeholder communication related to SIMHE-Metropolia services is operated via Liana®Cloud newsletter.

Microsoft Corporation and Metropolia’s email system

Newsletters related to SIMHE-Metropolia services are sent by email through Metropolia’s Microsoft Outlook Exchange email system. Although Metropolia has procured the email system as part of the Microsoft O365 service package, the system is operated on Metropolia’s own server.

Deltagon Group Oy and Security mail (Deltagon’s sec@gw -security mail solution)

Deltagon's sec@gw security e-mail solution can be used to forward sensitive personal data and confidential documents to e-mail addresses outside Metropolia (when e-mail is sent to a non-“@ metropolia.fi” e-mail address, or back to Metropolia).

Microsoft Corporation and Microsoft O365 Forms query tool and OneDrive

Microsoft Forms query tool is used for marketing of SIMHE services, stakeholder communication, customer communication and e.g. collecting feedback from projects. Microsoft OneDrive is used for providing guidance and counselling services and also for communication of project participants in Deploying Competences in Finland and SIMHEpath projects.

Google LLC and Google Forms query tool

Google Forms query tool is used for collecting feedback and other queries from projects.

Microsoft Corporation (part of the O365-package) Microsoft Teams web conferencing tool

Microsoft Teams is a web conferencing tool, which is used for remote steering In addition, Microsoft teams is used for communication with SIMHE partners and stakeholders.

Funet Miitti / NORDUnet, service provider CSC Oy and Zoom web conferencing tool

Zoom is a web conferencing tool (Funet Miitti / NORDUnet, service provider CSC Oy). Zoom is a web conferencing tool, which is used for remote steering as well as communication with SIMHE partners and stakeholders. The Center for Science Information Technology - IT Center for Science - CSC's Funet Miitti (Zoom) service is used at Universities of Applied Sciences. The service has been implemented jointly in co-operation with NORDUnet and is therefore not part of the publicly available Zoom service. In addition, the Zoom service provided by NORDUnet operates entirely in the EU, in server environments reserved for NORDUnet's own use. These servers are located in Denmark and Sweden. The services have also been agreed with NORDUnet and Zoom, taking into account the requirements of European data protection regulations (GDPR).

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

Personal data contained in the personal data register of SIMHE-Metropolia services 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 SIMHE-Metropolia services is, as a general rule, stored in the register as follows:

  • The personal data of participants of SIMHEpath project is processed within the EURA2014 system for EU Structural Fund projects and also stored in it.
  • Data concerning the application to higher education and the result of admission is processed in Studyinfo.fi-service, maintained by the Finnish National Agency for Education, and stored for five (5) years, starting from the decision of student admission. However, data concerning receiving the right to study is stored permanently.
  • Records of educational/training activities that award credits are stored permanently. These permanently stored credits are saved into Metropolia’s OMA/Peppi student registry system (forming part of Metropolia’s student registry). Activities awarding credits are addressed in the legislation on national study and degree certificates.
  • All data exported to student registry systems of universities of applied sciences, concerning the right to study, annual enrollment, compeleted degrees and studies and other data, is stored permanently in electronic format, from since the information has been available in electronic form
  • All data exported to VIRTA data warehouse, concerning the right to study, annual enrollment, completed degrees and studies, is stored permanently and solely in electronic format 

 

Documentation of SIMHE projects is stored for the prescribed time according to the requirements of the funder. The duration of the projects is as follows:

  • SIMHE continuation project, funded by the Ministry of Education and Culture, 1.3.2019-28.2.2021
  • The International talents accelerating growth project, Talent Boost AIKO funded, 1.5.2019-30.4.2021
  • SIMHEapp, funded by Ministry of Education and Culture, 1.9.2017 - 31.10.2019
  • SIMHEapp II, funded by Ministry of Education and Culture, 1.4.2019-31.12.2021
  • SOTE-silta project, ending 31.12.2020
  • Deploying Competence in Finland project, ending 31.12.2020
  • SIMHEpath, ending 31.12.2020

 

The following regulations have been observed when determining the retention times:

  • EU General Data Protection Regulation (“GDPR”, 2016/679)
  • Data Protection Act (1050/2018)
  • Universities of Applied Sciences Act (932/2014)
  • Decision of the National Archives of Finland on retention times – order given to universities of applied sciences concerning the permanent storage of data in electronic format (AL/20757/07.01.01.03.02/2016) 

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 SIMHE-Metropolia 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 was obtained.

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

In additition, the personal data has been collected from:

  • Studyinfo.fi-service (Opintopolku.fi-service), maintained by the Finnish National Agency for Education, regarding the application to higher education
  • OILI service of annual enrolment, maintained by the Finnish National Agency for Education, regarding the information of student’s enrolment as attending or as non-attending
  • The Population Register Centre

Automated individual decision-making, including profiling

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