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Introtext

Submitted on 26.2.2021 - 12:02

Name of the register

Personal data register of the Metropolia competence center functions for highly educated immigrants in the Helsinki region

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: Anne Karjalainen
Position: Project manager (Metropolia competence center functions for highly educated immigrants in the Helsinki region)
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: anne.karjalainen [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 the Metropolia competence center functions contains data regarding the customers of Metropolia SIMHE services / collaboration with the local government pilots on employment in Helsinki, Espoo and Vantaa-Kerava. Metropolia provides guidance and education services to recognise immigrants’ competence and to guide them to suitable education and career paths. The functions are designed and carried out in collaboration with the employment pilots of the cities of Helsinki, Espoo and Vantaa-Kerava.

The purpose of the personal data register of the Metropolia competence center functions is to provide suitable guidance and education services to the customers of the employment pilots.

The following privacy notices supplement the privacy notice of the Metropolia competence center functions:

Legal basis for the processing of personal data:

The processing of the personal data contained in the personal data register of the Metropolia competence center functions is based on consent obtained from the data subject. It is a matter consent, when a person completes the registration form and on the form confirms consent to the processing of personal data.

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 the Metropolia competence center functions are:

  • the customers using the services
  • the employees of the local government pilots on employment of Helsinki, Espoo and Vantaa Kerava and
  • the representatives of partner companies and organisations.

The following personal data of the customer/the representative of the employment services is stored in the personal data register:

  • Basic information of customers: forename(s), last name, gender, age group, nationality, native language, municipality of residence, e-mail address, phone number
  • Contact information of the representative of the employment services of the city: name, e-mail address, phone number
  • Data related to the customer’s work experience and job search: career goals, work experience, CV, link to e.g. LinkedIn profile
  • Data related to the customer’s education background: completed degrees and their language of tuition, other relevant higher education studies and international certificates, language skills

In addition, the customer/partner company or organisation can voluntarily register to following services including data collection:  

  • Subscription to a newsletter for customers (e-mail address)
  • Registration to events (forename(s), last name, e-mail address, phone number, organisation, title, special diet)

The customers participating in the education tracks will be registered to Metropolia’s student register and study-related systems. In their case the following privacy notices are applied:

In addition, as part of recognition of competence, copies of certificates related to customers’ studies and work experience as well as self-assessment of professional competence will be collected.

The following data is collected from the representatives of companies and other organisations to support the business coordinator’s work:

  • Basic information of the company representative(s): forename(s), last name, title, name of the company, phone number, e-mail address
  • Information on the collaboration: date of contact, form of collaboration, follow-up, website

The privacy notice of Personal Data Register of Metropolia Continuing Education and Enterprise Services supplements this privacy notice.

Regular sources of personal data

The personal data is mostly obtained from the data subjects themselves on the registration form and in the guidance discussions.

Information systems used in the processing of personal data

The data contained in the personal data register of the Metropolia competence center functions is processed using the various IT systems, applications and software procured by Metropolia. The following are used in the competence center functions:

Lyyti event and appointment management system

Lyyti is used for registering to the services and managing registrations to various events and group guidance sessions. The privacy notice of Personal Data Register of Metropolia Event Management supplements this privacy notice with regard to events.

E-form software

E-form is used for the customer’s self-assessment of competences on the education tracks. Additionally the e-form is in use for the voluntary registration to the SIMHE-services customer registry which is used for sending a customer newsletter.

Microsoft Teams web conferencing tool

Microsoft Teams web conferencing tool can be used for remote/online guidance, teaching and meetings.

Zoom web conferencing tool

Zoom is used for remote/online guidance, teaching and meetings. Metropolia uses the Center for Science Information Technology - IT Center for Science - CSC's Funet Miitti (Zoom) service. 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).

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

Sec@gw security e-mail solution can be used to forward sensitive personal data and confidential documents to and from e-mail addresses outside Metropolia.

Microsoft O365 Forms query tool and OneDrive

Microsoft Forms query tool is used for e.g. collecting feedback from customers. Microsoft OneDrive is used for sharing project documents, e.g. meeting memos, to the partner network.

Metropolia’s email system

E-mail communication takes place 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.

Liana®Cloud newsletter tool

The customer newsletter of Metropolia SIMHE services is sent to customers’ e-mail addresses using the Liana®Cloud newsletter tool. The tool can also be used for marketing events.

The following are used for processing personal data of the customers participating in the education tracks:

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. Customers register to courses through the open UAS registration system. Upon registration the personal data is saved in the OMA/Peppi system so that Metropolia user ID’s can be provided to customers and their credits can be permanently saved into the student registry. The OMA/Peppi system has been produced in-house in Metropolia and its use therefore does not require collaboration with external service providers.

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 as required by legislation. VIRTA is the national data warehouse for higher education.

Description of the groups of data subjects and personal data groups

Metropolia SIMHE services can give evaluations, recommendations and a summary of the career and education paths suggested on the basis of the guidance discussions to the employment pilots of Helsinki, Espoo and Vantaa-Kerava. Data may also be disclosed for statistical and research purposes related to the functions.

 

Access to the personal data contained in the personal data register of the Metropolia competence center functions 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:

Lyyti Ltd and Lyyti Event Management System

Lyyti is used for registering to the services and managing registrations to various events and group guidance sessions. The privacy notice of Personal Data Register of Metropolia Event Management supplements this privacy notice with regard to events.

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

Microsoft Teams web conferencing tool can be used for remote/online guidance, teaching and meetings.

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) which is used for remote/online guidance, teaching and meetings. 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).

Microsoft Corporation and Metropolia’s email system

E-mail communication takes place 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.

Leijonaverkot Oy (part of Erillisverkot group of companies, former Deltagon Group Oy) and security mail (Deltagon’s sec@gw -security mail solution)

Sec@gw security e-mail solution can be used to forward sensitive personal data and confidential documents to and from e-mail addresses outside Metropolia.

Microsoft Corporation and Microsoft O365 Forms query tool and OneDrive

Microsoft Forms query tool is used for e.g. collecting feedback from customers. Microsoft OneDrive is used for sharing project documents, e.g. meeting memos, to the partner network.

Eduix Ltd and the e-form software

E-form is used for the customer’s self-assessment of competences on the education tracks. Additionally the e-form is in use for the voluntary registration to the SIMHE-services customer registry which is used for sending a customer newsletter.

Liana Technologies Ltd and Liana®Cloud newsletter tool

The customer newsletter of Metropolia SIMHE services is sent to customers’ e-mail addresses using the Liana®Cloud newsletter tool. The tool can also be used for marketing events.

Additionally, the following systems apply to the customers taking part in the education tracks:

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 as required by legislation. VIRTA is the national data warehouse for higher education.

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

Personal data contained in the personal data register of the Metropolia competence center functions 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 the Metropolia competence center functions is, as a general rule, stored in the register as follows:

The personal data related to career guidance, guidance to education tracks and recognition of competence is stored for the period of time necessary to provide the service, maximum for the duration of the project 12 June 2020 - 31 December 2022.

The personal data related to the customers completing studies on the education tracks is stored according to the regulations on the student registries of Metropolia:

  • 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 
  • The data of the customers taking part in the nursing education track in March-April 2021 will be processed and stored as described in the privacy notice of the SOTE-silta project.

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

  • EU General Data Protection Regulation (“GDPR”, 2016/679)
  • Data Protection Act (1050/2018)
  • 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

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: 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)

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.

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.

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 the Metropolia competence center functions 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. Participation in the functions is voluntary.

Automated individual decision-making, including profiling

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