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.
User Register of Metropolia’s Requeste Service Request System
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: Kimmo Nikkanen
Position: Chief Information Officer, IT Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: mikko [at] metropolia.fi (kimmo[dot]nikkanen[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Mikko Mäkelä
Position: IT Services Manager/Help Desk Services, IT Services
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: mikko.makela [at] metropolia.fi (mikko[dot]makela[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 purpose of the User Register of Metropolia’s Requeste Service Request System and the personal data it contains is to register and manage the service requests sent by Metropolia’s students and staff concerning, in particular, IT Services such as various help desk tasks. The service request system may receive support requests related to digital pedagogy, descriptions of ICT problems sent by end users at Metropolia, IT procurement requests, queries about printing quotas, questions related to Halli project management, data protection notifications and data security breach notifications, security notifications and requests sent to the Facilities Management Services and the Library Services. All of these service requests are registered in the service request system called Requeste.
The service request system therefore contains data on the customers of IT services, Facilities Management Services, Security Services, and Library and Information Services (students as well as employees/lecturers who are members of staff), on the service requests sent by the customers and on the workstations and software used by the customers. The system is a combined customer register, customer service database and device and software register, and the data it contains are used for running the service request system.
The Privacy Notice for the Personal Data Register of Metropolia’s Information Management and IT Services supplements this Privacy Notice for the User Register of Metropolia’s Requeste Service Request System. All of the Privacy Notices for Metropolia’s personal data registers are available on the public website of Metropolia University of Applied Sciences in the Privacy Notices section.
Lawful basis for the processing of personal data:
The processing of the personal data in the User Register of Metropolia’s Requeste Service Request System is based on the statutory duties of a university of applied sciences (UAS) as set out in the Universities of Applied Sciences Act (932/2014), the functions supporting the core duties of the UAS as well as the execution of these in the public interest.
To a certain extent, the processing of the personal data in the User Register of Metropolia’s Requeste Service Request System is based on the consent of the data subjects. Placing a service request is a voluntary act.
The lawful basis for the processing of the personal data in the User Register of Metropolia’s Requeste Service Request System is not “legitimate interest”. Therefore this section does not apply.
The data subjects in the User Register of Metropolia’s Requeste Service Request System are Metropolia’s students and staff.
The following personal data are recorded in the User Register of Metropolia’s Requeste Service Request System:
Information on the data subject (student or employee/lecturer who is a member of staff):
- name
- job title
- email address at the university of applied sciences
- telephone number(s)
- first language
- work unit
- unit in the organisation
- office number and details on the property where the office is located
- supervisor (in the case of an employee/lecturer who is a member of staff)
- area of responsibility
- home page
- street address
- user IDs
- information on whether present or absent (students)
- arrival batch (students)
Information on the case filed in the Requeste service request system:
- ID number
- entry date
- service request classification
- name of workstation
- location
- space
- notifier
- telephone
- person in charge of the case
- urgency
- severity
- subject
- description
- solution
- history information
E-lomake (E-form) “Feedback to Help Desk”
- name of person providing feedback
- number of service request which the feedback concerns
Device data:
- name of the device
- type of the device
- supplier
- product name
- device role
- network area
- operating system
- service pack
- hardware details:
- model
- processor
- amount of memory
- serial number
- hard drive(s) (name, size)
- network card
- disc drives
- display - information on user
- hostname
- IP address
- DHCP/IP
- MAC address
- usage time
- serial number
- type
Device data are collected on workstations, servers and printers.
Software data:
- name of software
- version
- installation date
The information entered into the service request by the data subject of the Requeste service request system (student or employee/lecturer who is a member of staff):
DIGITAL PEDAGOGIC SUPPORT
- telephone number and email address of the data subject (student or employee/lecturer who is a member of staff)
- department/field of study
- location (school)
- subject and description of the issue which the service request concerns
- attachment file for the issue which the service request concerns
HALLI PROJECT MANAGEMENT
- telephone number and email address of the data subject (student or employee/lecturer who is a member of staff)
- subject and description of the issue which the service request concerns
- attachment file for the issue which the service request concerns
- location (school)
- attachment file for the issue which the service request concerns
DATA PROTECTION NOTIFICATION OR DATA SECURITY BREACH NOTIFICATION (GDPR)
- telephone number and email address of the data subject (student or employee/lecturer who is a member of staff)
- subject and description of the issue which the service request concerns
- attachment file for the issue which the service request concerns
SECURITY NOTIFICATION
- incident and where it took place
- person called to the scene
- level of severity
- location (school)
- damage caused
- time of the incident
- telephone number of the data subject (student or employee/lecturer who is a member of staff)
- subject and description of the issue which the service request concerns
- attachment file for the issue which the service request concerns
HELP DESK
- location (school)
- name of workstation
- room number
- subject and description of the matter which the service request concerns
- attachment file for the matter which the service request concerns
- telephone number of the data subject (student or employee/lecturer who is a member of staff)
IT PROCUREMENT
- location (school)
- product number
- party that has approved the procurement
- project number
- cost centre, room number and account
- subject and description of the matter which the service request concerns
- attachment file for the matter which the service request concerns
FACILITIES MANAGEMENT SERVICE
- location (school)
- object that requires maintenance
- room number or space
- subject and description of the matter which the service request concerns
- attachment file for the matter which the service request concerns
- telephon number of the data subject (student or employee/lecturer who is a member of staff)
LIBRARY SERVICES
- job queue (subject)
- library
- further details
- telephone number of the data subject (student or employee/lecturer who is a member of staff)
- subject and description of the matter which the service request concerns
- attachment file for the matter which the service request concerns
If the data subject (student or employee/lecturer who is a member of staff) is working remotely or for some other reason is not connected to Metropolia’s internal network, a remote connection may be formed, with the data subject’s consent, using the TeamViewer remote connection tool.
Through the TeamViewer remote connection tool, IT Services is able to view the user’s computer screen, which may display personal data, confidential documents and other sensitive information or documents. In the TeamViewer remote connection tool, telecommunications are transmitted through a server of the service provider, TeamViewer Germany GmbH, which is the processor of the personal data in accordance with the EU’s General Data Protection Regulation (GDPR). For more details, see section 8 of this Privacy Notice.
The personal data are mainly obtained from the data subjects themselves.
In addition, regular sources of personal data include the following:
Customer information:
- LDAP directory
- IT support personnel from IT Services
Case information:
- the customer fills this in
- IT support personnel from IT Services supplement the information
Device and software register:
- The Requeste service request system includes auditing software
that creates an inventory of devices used to fetch data on the devices - help desk and ICT support personnel for the faculties and IT centre
Access to the personal data contained in the User Register of Metropolia’s Requeste Service Request System 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.
The service requests received by the system are routed within the system to the recipients whom the service request concerns, in accordance with the service address used in the contact. A service request is only accessible to the persons whose work duties require them to use the register. Separate processor groups are assigned in the register to the different service addresses and they process service requests in their separate service request queues.
With respect to the systems used by the User Register of Metropolia’s Requeste Service Request System, personal data processing agreements in accordance with Article 28 of the GDPR have been or will be concluded with the following cooperation partners:
Sysart Oy; Requeste service request system
Requeste is a service request and work management system developed by Sysart Oy and intended for use by work groups. Requeste is a browser-based customer interface through which users can send service requests to the different service teams at Metropolia. The Requeste service request system includes auditing software that creates an inventory of devices that is used to fetch data on the devices.
Eduix Oy; E-lomake (E-form) software
E-lomake is used to collect feedback for Metropolia’s Help Desk. The E-lomake software is operated on Metropolia’s own server.
TeamViewer Germany GmbH; TeamViewer remote connection tool
The TeamViewer remote connection tool provided by TeamViewer Germany GmbH is used by Metropolia’s Help Desk to provide support services by forming a remote connection to the computer of the data subject who sends a support request (student or employee/lecturer who is a member of staff). If the data subject is working remotely or for some other reason is not connected to Metropolia’s internal network, a remote connection may be formed using the TeamViewer remote connection tool. The Help Desk will not unilaterally initiate a remote connection through TeamViewer to the data subject’s computer, but instead the remote connection must always be agreed on separately in the support call or service request. The data subject’s consent is required for forming a remote connection.
Through the TeamViewer remote connection tool, IT Services are able to view the user’s computer screen, which may display personal data, confidential documents and other sensitive information or documents. In the TeamViewer remote connection tool, telecommunications are transmitted through a server of the service provider, TeamViewer Germany GmbH, which is the processor of the personal data in accordance with the EU’s General Data Protection Regulation (GDPR). The company processes data through the TeamViewer remote connection tool and the servers of third parties subordinated to it that process data, but it does not collect or save any of the data.
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 retention times for the personal data collected and processed in the User Register of Metropolia’s Requeste Service Request System vary depending on the subject of the service request. The retention time ranges from one year to several years.
The retention time is based on Metropolia’s archiving plan.
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.
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.
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 User Register of Metropolia’s Requeste Service Request System 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 were obtained.
The personal data stored in the User Register of Metropolia’s Requeste Service Request System have mostly been obtained from the data subjects themselves.
The data subject personally fills in the service requests sent to the Requeste service request system and gives their consent for the processing of their personal data.
In addition, personal data may be obtained through the TeamViewer remote connection tool if the data subject gives their consent to IT Services for viewing the user’s computer screen, which may display personal data. Furthermore, IT Services may obtain additional data from the LDAP directory and supplement the service request.
The User Register of Metropolia’s Requeste Service Request System and the personal data it contains are not used for automated decision-making or profiling.