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.

Name of the register

Personal data register of the Hytke project of Metropolia University of Applied Sciences

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:
Position: Head of department/Head of degree programme/Supervisor
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail:

Contact details of the contact person for the register:

Name:
Position:
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail:

Contact details in questions concerning the purpose of the register:

e.g. kyla [at] metropolia.fi

Data Protection Officer

Riikka Ikäheimonen, Metropolia’s Data Protection Officer
Tel: +358 50 565 8499
Email: tietosuojavastaava [at] metropolia.fi

Purpose and legal basis of the processing of personal data

Purpose of the processing of personal data:

The purpose of the personal data register of the Hytke project of Metropolia University of Applied Sciences and the personal data it contains is to carry out project’s development activities and to receive registrations for events. Joining the personal data register of Metropolia’s Hytke project is voluntary.

 

Legal basis for the processing of personal data:

The processing of personal data contained in the personal data register of Metropolia’s Hytke project is based on the consent obtained from the registered person.

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 the Hytke project of Metropolia University of Applied Sciences 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 Metropolia’s Hytke project are the partners of the project and students, personnel and stakeholders of Metropolia University of Applied Sciences.

The following personal data are stored in the personal data register of Metropolia University of Applied Sciences:

 

BASIC INFORMATION AND CONTACT DETAILS

  • Forename(s) and surname
  • Email address
  • Telephone number
  • Contact information
  • Title/role/responsibility
  • Organization/company/community

The personal data may also include the voice of the person, who voluntarily participate in the data collection of the Hytke project, such as co-creation or interviews that are recorded.

 

INFORMATION RELATED TO PARTNERSHIP, COOPERATION AND COMMUNICATION

  • Terms of ordering and canceling project services
  • Feedback
  • Audiovisual recordings of events, for example with Zoom or Teams

 

CONSENT FOR AND INFORMATION ON CERTAIN ACTIONS

  • Registration forms: The registration forms ask for the basic and contact information described above and for consent to use the contact information for activities and communication of the project.

Consent forms: with the consent form, the participant gives his or her consent to voluntary participation and the collection of personal data in the development activities of the Hytke project, such as discussions and co-creation. The consentor states that he has read the relevant bulletin.

Regular sources of personal data

Collecting name and other contact information is based on cooperation or other connection with the Hytke project. The personal data are obtained from the data subjects themselves.

Personal information may also be obtained from other sources as well.

Description of the groups of data subjects and personal data groups

Access to the personal data contained in the personal data register of the Hytke project of Metropolia 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 the Hytke project of Metropolia, personal data processing agreements in accordance with Article 28 of the GDPR have been concluded with the following cooperation partners:

 

Google Drive, Google Forms, Google Jamboard and Google LLC

Google applications, contained in the Metropolia’s Google Suite for Education service package, can be used in the Hytke project to share materials and documents, to co-working, to collect registrations and feedback and to collect anonymous data for example in co-creation.

 

E-lomake

E-lomake, the form software used in Metropolia University of Applied Sciences, can be used as a registration and feedback form.

 

Microsoft Corporation and Microsoft O365 services (Forms, OneDrive, SharePoint)

Microsoft Forms is a survey tool that can be used in the Hytke project to collect registrations and feedback. Microsoft One Drive and SharePoint can be used in the Hytke project to share materials and documents and for co-working.

 

Microsoft Corporation and Microsoft Teams web conferencing tool

Microsoft Teams web conferencing tool is used to communicate and transmit information within the Hytke project.

 

Service provider CSC Oy and Zoom web conferencing tool

Zoom is a web conferencing tool (Funet Miitti / NORDUnet, service provider CSC Oy - The Center for Science Information Technology - IT Center for Science). Zoom web conferencing tool is used to communicate and transmit information within the Hytke project. CSC's Funet Miitti (Zoom) 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).

 

YouTube video sharing service and Google LLC

YouTube is a video sharing service that is contained in the Metropolia’s Google Suite for Education service package. YouTube can be used to save and share videos, produced in the Hytke project, in Metropolia’s You Tube channel. No personal data will be collected without the consent of the data subject.

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

As a general rule, personal data contained in the personal data register of Metropolia’s Hytke project 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.

 

The ICT service provider of Metropolia UAS may not transfer or grant access to personal data or process personal data of Metropolia UAS outside the EU or the EEA without prior consultation and prior written consent received from Metropolia UAS.

 

In the case of written consent has been received from the data controller (Metropolia UAS) for the personal data transfer outside the EU or the EEA, a documented TIA (Data Transfer Impact Assessment) must be conducted and approved by the data controller. Before personal data can be transferred outside the EU or the EEA, the data exporter (Metropolia UAS) of personal data must ensure that an adequate level of data protection is guaranteed for the personal data to be transferred. If the basis for the transfer does not guarantee adequate protection in itself, it can be supplemented in certain cases with different kinds of technical, organisational or agreement-based additional safeguards.

 

The controllers and processors of personal data that are transferring the data must check on a case-by-case basis if the legislation of the third country guarantees a level of protection for the personal data to be transferred that is essentially equivalent to that of the EU and of the EEA. The assessment must take account of the case-by-case conditions of the transfer, the legislation of the third country in question and the applicable basis for the transfer. The data exporter (Metropolia UAS) is responsible for drawing up a concrete assessment. The assessment must also be documented carefully.

 

In the case of written consent received from the data controller/data exporter (Metropolia UAS) for the personal data transfer outside the EU or the EEA, the contract bounding the data transfer must include Standard Contractual Clauses (SCC) adopted by the EU Commission. In addition, the data controller/data exporter (Metropolia UAS) must assess and follow-up on a regular basis the level of data protection in the destination country. The data controller/data exporter (Metropolia UAS) may negotiate with the 

ICT service provider whether some additional safeguards - like technical, organizational or agreement-based additional safeguards - might be used when transferring data from the EU or the EEA outside the EU or the EEA. The data transfer might be conducted also by using an other data controller’s written approved mechanism.

 

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.

Personal data retention times

The personal data collected for and processed within the personal data register of Metropolia’s Hytke project are, as a general rule, stored in the register until the end of the project (December 31, 2023). All the personal data collected during the project will be deleted at the end of the project, no later than January 2024.

 

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)

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

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).

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.

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 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, 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

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: Ratapihantie 9, 6th floor
00520 Helsinki, Finland
Postal address: PO Box 800
FI-00521 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 enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequen

Information on whether the provision of personal data for processing in the personal data register of the Hytke project of Metropolia University of Applied Sciences 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 register of the Hytke project of Metropolia University of Applied Sciences is based on voluntary registration and it is used to manage the activities and services of the Hytke project.

 

- It is not compulsory to be registered in the personal data register of the Hytke project of Metropolia University of Applied Sciences

 

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

Automated individual decision-making, including profiling

The personal data register of the Hytke project of Metropolia University of Applied Sciences and the data contained in it will not be used in automated decision-making or profiling.