See Privacy Notice for Personal Data Register of the Urban SOS-Project.
Personal data register of the Urban SOS-Project of Metropolia
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: Annakaisa Oksava
Position: Head of School, the School of Wellbeing
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: annakaisa.oksava [at] metropolia.fi (annakaisa[dot]oksava[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Tiina Lehto-Lundén
Position: Project Manager, the School of Wellbeing
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: tiina.lehto-lunden [at] metropolia.fi (tiina[dot]lehto-lunden[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 goal of the international Erasmus + funded Urban SOS project is to develop educational activities that are focused on the growing need of the social field to take part in both international and multiprofessional dialogues.
We would like to activate the discussion on what affects the residents’ wellbeing in the urban surroundings. We invite both the residents and the educators in the field of social studies into this dialogue together with the agents working in the field and the local authorities executing urban policies.
The aim of the Urban SOS is to analyse both the urban social work and the structures of the social support and communities to help create sustainable solutions for the residents and the cities.
During the project, we will develop four “products”:
- Creating an approach based on common practices that is research based, analytical and methodological
- Training material for the teaching staff
- E-learning material for the professionals in the social field
- Creating an online learning community. We use gamification methods to increase student engagement, motivation and knowledge.
The personal data included in the personal data register of Metropolia’s Urban SOS -project will carry out e.g. the following processing operations.
- communicating and informing the project activities
- organizing events and development workshops
- taking photos and videos in the events and development workshops of the project
The current privacy policy of Metropolia's Urban SOS personal data register is supplemented by the following registers with their privacy policy.
OPH general privacy policy
The general privacy policy of the European Commission
Legal basis for the processing of personal data:
The legal basis for processing the personal data in the personal data register of Metropolia’s Urban SOS project is:
- consent given by the data subject
- the public interest (other personal data collected in the project and their processing is based on the public interest)
The legal basis for the processing of personal data contained in Personal Data Register of the Urban SOS-Project of Metropolia University of Applied Sciences is not “legitimate interests”. Therefore this section does not apply.
The following personal data are stored according to the personal data groups into the personal data register of the Urban SOS project at Metropolia:
Teachers of social services at Metropolia
- basic information on the teachers of the degree programme of social services: first name; surname; date of birth, street address; postal address; city; phone number, e-mail
- Information on action aimed at data subjects: consent to receive newsletters; consent to receive direct marketing by e-mail and/or information on other forms of cooperation
- Photographs and videos: photographs and video recordings taken at the events and development workshops of the project. Photos and videos are used on the project website as well as in other communication.
Metropolia students:
Basic information on the students of Metropolia: first name; surname; date of birth; street address; postal code; city; telephone number; e-mail address
- Study and degree information: the degree; the degree program; the stage of studies; type of studies (internship, theoretical studies, innovation studies, final thesis, elective studies)
- The personal data on the contracts regarding the final thesis (e.g., the personal data of the signed participants)
- Information on the procedures targeted at the data subjects: consent on receiving newsletters; consent on direct marketing by e-mail and /or information on other co-operation.
- Photos and videos: photos and video recordings taken at the development workshops and events of the project. Photos and videos are used on the project web pages and in other forms of communication.
The professionals in the project:
- The basic data concerning the professionals in the project: first name, surname, date or birth, street address, postal code, the city, the telephone number, the e-mail address
- Information on the procedures aimed at the data subjects: consent to receive newsletters; consent to direct marketing via the e-mail or/and information on other forms of co-operation
- Photographs and video recordings: photographs and video recordings taken in the events and development workshops of the project. The photos and video recordings are used on the web sites of the project as well as other forms of communication.
The interest groups in the project:
- Photos and video recordings: photographs and video recordings taken in the events and development workshops of the project. The photos and video recordings are used on the web sites of the project as well as other forms of communication. The persons of these groups can be seen in the pictures and in the video recordings.
The personal data have been obtained from the data subject himself or herself.
In addition, the Metropolia Urban SOS project data register is substantially linked to Metropolia Urban SOS project’s research data, its personal register and the privacy policy based on herein that be read after the section 17 of this privacy policy.
When broadly interpreting the Article 4.9. of the EU General Data Protection Regulation, the recipients to whom the controller either transfers their personal data or transfers personal data for processing (e.g. using a technical interface when performing maintenance tasks) are listed below.
The personal data in the Metropolia Urban SOS project’s data register are granted access, should the need arise:
Regarding the operation of the Urban SOS -project at Metropolia, the personal data processing agreements in accordance with Article 28 of the GDPR are drawn up centrally by Metropolia’s information administration with the following co-operating partners:
Metropolia E-mail system
The informing e-mails related to the Metropolia Urban SOS -project, e.g. event invitations (if the data subject has given an explicit written consent), takes place via the Microsoft Outlook Exchange E-mail system.
Even though Metropolia has acquired an e-mail system as a part of the Microsoft O365-package plan, Metropolia’s e-mail system operates using the school’s own server.
E-form software
The events and development workshops of Metropolia’s Urban SOS -project are signed up to with an e-form, from which the data are transferred into Excel to manage the participant data.
The newsletter tool Liana®Cloud (e.g. newsletter submission)
The e-mailed information regarding to the personal data register and activities in the Urban SOS project at Metropolia, in case the data subject has given an explicit written consent is carried out via Liana®Cloud newsletter tool.
Google LLC and YouTube video tool
Videos produced in the Metropolia Urban SOS project are saved on the YouTube channel of Metropolia University of Applied Sciences using the YouTube video tool.
Facebook Inc. and Instagram photo and video tool
Photos and/or videos taken in the Metropolia Urban SOS project are saved with the Instagram photo and video tools.
Facebook Inc. and Facebook social media tools
Photos or videos taken during the Metropolia Urban SOS project can be saved or linked to Metropolia’s Facebook account.
Twitter Inc. and Twitter community and micro blog service
Photos and/or videos taken in the Urban SOS project can be saved or linked to Metropolia’s Twitter account.
Metropolia’s blogs
The blog texts and photos and/ or videos taken in the Urban SOS project are saved and linked to the Metropolia blog platform.
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 personal data collected in the personal register of the Metropolia Urban SOS project will be saved permanently in an electronic form in the National Archives of Finland in accordance with the regulation for the permanent storage period concerning the Universities of Applied Sciences.
Such personal data collected in the project are exceptions where the processing and the saving period are included in the following separate personal data registers, which have their unique specified saving periods, e.g. due to the requirement from the sponsor:
- the personal data register of the Metropolia.fi website
- the project management register
- the permanent storage period stated by the National Archives of Finland concerning the UAS regulates saving other information within the project.
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.
In case the processing of the personal data is based on the consent given by the data subject, the data subject has the right to cancel his or her consent at any point without it affecting the lawfulness of the prior processing.
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 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.
The processing of the personal data contained in the personal data register of Metropolia takes place in relation to whether the data delivery requires legal, contractual or contractual requirement, and whether the data subject is obliged to provide his or her personal data and the consequences of not providing the data. It has also been determined on a register-by-register basis where the personal data were obtained.
• The personal data register of Metropolia’s Urban SOS project is a personal register based on voluntary access, with which the project's activities, communications and current information of the project are managed.
• It is not compulsory for anyone to become a member of the personal data register of Metropolia Urban SOS project.
• The personal data saved in the register has, in principle, been obtained from the registered person himself/herself
The personal data within the personal data register of Metropolia’s Urban SOS are not used in the automatic decision making nor profiling.