Tietosuojaseloste perustuu EU:n tietosuoja-asetuksen (2016/679, General Data Protection Regulation, ”GDPR”) rekisteröityjen informointivelvoitteeseen (GDPR:n artiklat 12-14), GDPR:n artiklan 30 mukaiseen rekisterinpitäjän velvoitteeseen ylläpitää selostetta vastuullaan olevista käsittelytoimista sekä GDPR:ää täydentävän kansallisen tietosuojalain (1050/2018) velvoitteisiin.
Tämä tietosuojaseloste on lisäksi pyritty laatimaan saavutettavaksi EU:n ns. saavutettavuusdirektiivin ja sitä täydentävän kansallisen digipalvelulain vaatimuksiin pohjautuen (Euroopan parlamentin ja neuvoston direktiivi (2016/2102) julkisen sektorin elinten verkkosivustojen ja mobiilisovellusten saavutettavuudesta (2016/2102); Laki digitaalisten palvelujen tarjoamisesta (306/2019)).
Personal data register of TOKASA-project´s entrance examination
Metropolia University of Applied Sciences Ltd and Tampere University of Applied Sciences Ltd are joint controllers.
Contact information:
Metropolia University of Applied Sciences Ltd
Postal address: P.O. Box 4000, FI-00079 Metropolia
Visiting address: Myllypurontie 1, 00920 Helsinki, Finland
Telephone (switchboard): + 358 9 7424 5000
Tampere University of Applied Sciences Ltd
Postal and visiting address: Tampere University of Applied Sciences
Kuntokatu 3, FI-33520 Tampere, Finland
Telephone (switchboard) +358 (0)294 5222
Person responsible for the content of the register:
Name: Päivi Rimpioja
Position: Project Manager
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: paivi.rimpioja [at] metropolia.fi (paivi[dot]rimpioja[at]metropolia[dot]fi)
Name: Sanna Laiho
Position: Project Manager
Address: Tampere University of Applied Sciences, Kuntokatu 3, FI-33520 Tampere, Finland
E-mail: sanna.laiho [at] tuni.fi (sanna[dot]laiho[at]tuni[dot]fi)
Contact details of the contact person for the register:
Päivi Rimpioja, Metropolia UAS
Sanna Laiho, Tampere UAS
Contact details in questions concerning the purpose of the register:
Päivi Rimpioja, Metropolia UAS
Sanna Laiho, Tampere UAS
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 purpose of processing personal data is to carry out student selection for the Bachelor´s degree programme in Nursing.
Entrance examination for the Bachelor´s degree programme in Nursing is a joint entrance examination with Metropolia University of Applied Sciences Ltd and Tampere University of Applied Sciences Ltd. Examination is organized online and includes a video interview in addition to the question section.
Metropolia University of Applied Sciences Ltd and Tampere University of Applied Sciences Ltd are joint controllers who determine the purposes and means of the processing.
All applicants have the opportunity to test the programs used in the entrance examination at the time announced by the universities of applied sciences before the actual entrance examination. The same privacy policy applies to testing as to the actual entrance examination. The purpose of the testing is to give the applicant an opportunity to get to know the program in advance, that the actual entrance examination can be completed smoothly.
Legal basis for the processing of personal data:
The processing of the personal data collected to register of entrance examination for Bachelor’s degree programme in Nursing is based on:
legal obligation to which the controllers are subject, in accordance with Universities of Applied Sciences Act (932/2014) and Act on the National Registers of Education Records, Qualifications and Degrees (884/2017).
In addition, processing of the personal data is based on given explicit consent obtained from the data subject when the processing concerns special categories of the personal data such as biometric data (e.g. video material and voice in which persons are identifiable). These personal data are under the special protection in Article 9 of the EU’s General Data Protection Regulation.
The legal basis for the processing of personal data contained in the personal data register of Metropolia University of Applied Sciences and Tampere University of Applied Sciences is not “legitimate interests”. Therefore this section does not apply.
The data subjects in the personal data register of Metropolia University of Applied Sciences and Tampere University of Applied Sciences are:
- Applicants
The following personal data are stored in the personal data register of Metropolia University of Applied Sciences and Tampere University of Applied Sciences:
BASIC INFORMATION AND CONTACT DETAILS
- forename(s), surname, personal identity code, telephone number, email address.
- application identifier
- information concernin date of the entrance examination
2. DATA CONCERNING IDENTIFICATION OF THE APPLICANT
- The applicant prepares to present his/her identification card during all steps of the application process. The applicant may be asked to present his/her identification card on the web conferencing tool Zoom or Teams or by telephone.
- A passport, an identity card (Finnish or another EU country) or a Finnish driving license are acceptable proofs of the card holder’s identity. No other certificates will be accepted.
- Interviews or entrance examination occasions are not stored.
- Personal Moodle ID is sent to the applicant, in order to log in to Moodle (open-source learning platform).
3. APPLICANT’S ANSWERS
- Exam answers given in the entrance examination.
- Logging data related to the entrance examination answers: the exact time the answer was saved.
- Recorded video interview (oral and visual interview submitted on the examination platform ).
4. APPLICANT’S ENTRANCE EXAMINATION SCORE
The data processed at the end of the entrance examination and the data transmitted from Metropolia University of Applied Sciences to My -Studyinfo service (Opintopolku.fi-palvelu),is technically maintained by Finnish National Agency for Education:
- Applicant’s entrance examination score
Metropolia University of Applied Sciences stores the scores obtained from the data subjects (applicants) and these section-specific scores of the applicants’ entrance examination are transmitted to Studyinfo -service (Opintopolku.fi-palvelu).
The personal data are obtained from the data subjects themselves when they have submitted their application in Opintopolku.fi-service.
Access to the personal data contained in the personal data register of the entrance examination of Bachelor´s degree programme in Nursing 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 entrance examination of Bachelor´s degree programme in Nursing, personal data processing agreements in accordance with Article 28 of the GDPR have been concluded with the following cooperation partners:
- none -
As a general rule, personal data contained in the personal data register of Metropolia University of Applied Sciences and Tampere University of Applied Sciences 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.
The personal data collected for and processed within the register of entrance examination for Bachelor's degree programme in Nursing, as a general rule, stored in the register for a year from the date of the student selection decision.
The personal data in the register of applicants for higher education institutions is kept for five years, starting from the decision of student admission. Data concerning the right to study and National learner ID is kept forever. (Act on the National Registers of Education Records, Qualifications and Degrees 884/2017).
The following regulations have been also 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)
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.
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.
Every data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of their personal data infringes the applicable data protection regulations.
The national supervisory authority in Finland is the Office of the Data Protection Ombudsman. Contact details:
Office of the Data Protection Ombudsman
Street address: Lintulahdenkuja 4, 00530 Helsinki, Finland
Postal address: PO Box 800
FI-00531 Helsinki
Telephone (switchboard): + 358 29 56 66700
Fax: + 358 9 56 66735
Email: tietosuoja [at] om.fi (tietosuoja[at]om[dot]fi)
General description of the technical and organisational security measures aiming at protecting the personal data of the data subjects and the personal data registers:
- The protection of the register has been agreed upon with the system providers. If necessary, the responsibilities have been described in adequate detail in the appropriate agreements.
- The employees and other personnel have undertaken to comply with the obligation of secrecy and to keep confidential the information they receive in connection with the personal data processing.
- The system providers (personal data processors) undertake to maintain the register and the personal data relating to it in accordance with good data processing practices and comply with the obligation to absolute secrecy and confidentiality.
- The data security of the personal data register of the data controllers and the confidentiality of the data contained therein are ensured with appropriate technical and administrative means in accordance with good data processing practices.
- The data controllers have restricted user rights and authorisations to data systems, tools and other storage platforms in such a way that they can only be accessed and processed by the persons who are necessary for such processing due to their job duties or position.
- The system containing personal data may only be used by employees who are entitled to process personal data due to their job duties and/or position. Such employees will be given the appropriate training for their duties.
- Every user of a tool/system must identify themselves with their personal codes, which are issued when the right to access the tool/system is granted. The right of access will expire once the employee resigns or is transferred from the duties for which they were granted the right at Metropolia.
- The data are collected in databases that are protected logically and physically.
The databases and their back-up copies are located in locked premises, and the data can only be accessed by certain pre-appointed persons.
Information on whether the provision of personal data for processing in the register of entrance examination for Bachelor's degree programme in Nursing 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 has been obtained from the data subjects themselves regarding the application to higher education and participation in the entrance examination.
The personal data has also been obtained from Studyinfo -service (Opintopolku.fi-palvelu), maintained by the Finnish National Agency for Education, regarding the application to higher education and participation in the entrance examination.
Applying to the University of Applied Sciences as a student is arranged in such a way that when the applicant starts to fill in personal data of herself/himself through the Studyinfo -service (Opintopolku.fi-palvelu), the applicant will be informed in this connection that the personal data will be processed by the Finnish National Agency for Education and Metropolia University of Applied Sciences.
The personal data register of entrance examination of bachelor´s degree programme in nursing and the data contained in it will not be used in automated decision-making or profiling.