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.
Administrative Register for Project Activities at 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: Kimmo Virta
Position: Director, Project Management, Financial and Administrative Services at Metropolia
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: kimmo.virta [at] metropolia.fi (kimmo[dot]virta[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Antti Laurikainen
Position: Manager, R&D Development Services, RDI Activities
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: antti.laurikainen [at] metropolia.fi (antti[dot]laurikainen[at]metropolia[dot]fi)
Contact details for questions regarding the purpose of the register, email: tki [at] metropolia.fi (tki[at]metropolia[dot]fi)
Suvi Väänänen, Metropolia’s Data Protection Officer
Email: tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi) phone: .+358 40 844 0690
Purpose of the processing of personal data:
The purpose of the Administrative Register for Project Activities at Metropolia and the personal data it contains is the management of contacts, communications, announcements and financial reporting related to projects and RDI activities at Metropolia. The register contains data on Metropolia’s project activities, project staff, collaborating parties (organisations and contact persons) and costs and funding related to projects.
The following processing of personal data takes place in the Administrative Register for Project Activities at Metropolia:
- management of funders’ contact details
- management of the contact details of project participants from outside Metropolia
- personal data processing activities related to project communications and announcements
- management of financial reporting for projects
The Halli project management system used at Metropolia is connected to a system for monitoring the working hours and work plan of project participants from Metropolia. In the case of old projects, the Reportronic project management system is used. Therefore the personal data in the Administrative Register for Project Activities at Metropolia are also processed in connection with these activities.
Lawful basis for the processing of personal data:
The processing of personal data in the Administrative Register for Project Activities at Metropolia is based on:
- public interest,
- exercise of official authority and
- statutory obligation of the data controller (among others, Universities of Applied Sciences Act 932/2014, as amended in 941/2017).
The lawful basis for the processing of the personal data in the Administrative Register for Project Activities at Metropolia is not “legitimate interest”. Therefore this section does not apply.
M
The following personal data, among others, are stored in the Administrative Register for Project Activities at Metropolia:
Basic details and contact details for communications and announcements from the projects as well as working hours monitoring and salary transfers through the Halli/Reportronic system:
- First name; Surname;
- Role in the project;
- Job title; Organisation; Work location;
- Email address; Phone number;
- User rights level in the Halli/Reportronic project management systems and necessary information for working hours monitoring and salary transfers.
Personal data related to the reporting on contractual matters, costs and funding of the project, as well as financial reporting in the project:
- The personal data on signatories to agreements, which are contained in the Dynasty case and contract management system (Forename; Surname; Job title; Organisation),
- The personal data on signatories to funding agreements, which are contained in the Halli/Reportronic project management system (Forename; Surname; Job title; Organisation),
- personal data consisting of contact details related to financial reporting (Forename; Surname; Job title; Organisation).
The personal data belonging to the partner organisations of Metropolia’s project activities and their contact persons are maintained either in the Halli or the Reportronic project management system. The personal data are obtained from documents related to the project in question, such as funding applications, project plans and agreements. The basic details of project participants from Metropolia are transferred from the information systems of Human Resources Management or they are maintained directly in the Halli/Reportronic system.
Access to the personal data contained in the Administrative Register for Project Activities at Metropolia will be given, where necessary, in the systems listed below (using administrator rights; for example, for the purpose of repairing a technical fault in a measurement device, access will be given to the system provider or its maintenance personnel). 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 register, personal data processing agreements in accordance with Article 28 of the GDPR have been or will be concluded with the following cooperation partners:
Thinking Portfolio Oy; Halli project management system
The basic details of project participants from Metropolia are transferred from the information systems of Human Resources Management or they are maintained directly in the Halli or Reportronic system. In the case of old projects, the Reportronic project management system is used.
Sebitti Oy; Reportronic project management system
The basic details of project participants from Metropolia are transferred from the information systems of Human Resources Management or they are maintained directly in the Halli or Reportronic system. In the case of old projects, the Reportronic project management system is used.
Microsoft Corporation; Metropolia’s 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.
Microsoft Corporation; Microsoft-based cloud service tools approved by Metropolia
The cloud services in the Tools menu of the OMA intranet include Microsoft-based cloud services, which are involved in the processing of the personal data collected in project activities and in the saving of documents containing personal data.
Google LLC; Google-based cloud service tools approved by Metropolia
The cloud services in the Tools menu of the OMA intranet include Google-based cloud services, which are involved in the processing of the personal data collected in project activities and in the saving of documents containing personal data.
Innofactor Plc; Dynasty case and contract management system
The agreements concerning Metropolia’s project activities as well as the data on the signatories to the agreements and the project partners are stored in Metropolia’s joint case and contract management system.
As a general rule, the personal data contained in the Administrative Register for Project Activities at Metropolia are not transferred outside the EU or EEA or to international organisations.
The personal data contained in the register may be transferred outside the EU or EEA for the provision of IT services that are necessary for working or completing studies, based on a case-by-case consideration. The state to which personal data are transferred is the United States. It is also possible that personal data may be transferred to India, a country where, for example, global ICT service providers frequently base their help desk operations or ICT user support functions.
The international transfer of personal data from a personal data register of Metropolia University of Applied Sciences to the United States and/or elsewhere outside the EU or EEA is secured primarily with measures, i.e. Standard Contractual Clauses, provided for in Chapter V, Article 46 of the EU’s General Data Protection Regulation (GDPR). The Standard Contractual Clauses are included in agreements with ICT service providers concerning the processing of personal data.
Only the necessary data are transferred and the transfer is carried out in accordance with data protection legislation and within the restrictions placed by it. A separate agreement is always concluded on data security during the transfer.
As a general rule, the personal data collected and processed in the Administrative Register for Project Activities at Metropolia are stored permanently in the register in accordance with section 13 of the decision of the National Archives of Finland issued on 12 September 2017 concerning universities of applied sciences (Decision of the National Archives of Finland, registration number: AL/20757/07.01.01.03.02/2016, section 13 “Research, development and innovation (RDI) activities”): https://oma.metropolia.fi/delegate/desktop_web_content_attachment/attachment/6480597
The document information concerning competitive tenders for RDI projects (procurement documents) are stored for a fixed period of time.
The data subjects have the right to receive confirmation from the data controller of whether their personal data are being processed. Furthermore, the data subjects have the right of access to their personal data and the right to inspect their personal data stored in the register and to receive copies of them. Under the GDPR, the data controller must respond to requests by the data subjects to exercise their rights within one month of receiving such a request.
A. Right of access to personal data
The data subjects have the right to check whether their personal data are stored in the personal data register. A data subject may submit a request for information by delivering the data subjects’ information request form, which can be found on Metropolia’s public website and/or Metropolia’s intranet, to one of the three offices of Metropolia’s Student and Admission Services. The form must be filled in carefully, printed and signed personally by the data subject. If the data subject is a member of staff, they can deliver the request form to Metropolia’s Human Resources Management unit. When submitting the request, the data subject must prove their identity in a reliable manner (for example by presenting an official personal identity document or driving licence to the Metropolia employee receiving the request).
The visiting addresses of the offices of Metropolia’s Student and Admission Services are:
Metropolia’s Myllypuro campus
Myllypurontie 1, 00920 Helsinki, Finland
Metropolia’s Arabia campus
Hämeentie 135 D, 00560 Helsinki, Finland
Metropolia’s Myyrmäki campus
Leiritie 1, 01600 Vantaa, Finland
The visiting address of Metropolia’s Human Resources Management unit is:
Metropolia’s Myllypuro campus (Buildings C and D, 5th floor)
Myllypurontie 1, 00920 Helsinki, Finland
All information requests will be forwarded from the offices of Metropolia’s Student and Admission Services and/or the Human Resources Management unit to Metropolia’s Data Protection Officer (email: tuulia.aarnio [at] metropolia.fi (tuulia[dot]aarnio[at]metropolia[dot]fi), tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]fi)).
Metropolia’s Data Protection Officer will respond to information requests 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 denies that their personal data is correct (right to rectify personal data), in which case processing will be restricted until the data controller can ascertain that the data is correct;
- processing is unlawful 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)
Partially applicable. Article 20 of the General Data Protection Regulation introduces a new right of the data subject: the right to receive their personal data in a “structured, commonly used and machine-readable format” and the right to transmit those data to another controller. The purpose of this right is to increase the opportunities available to data subjects to influence their personal data because this facilitates the transfer or copying of personal data from one data system environment to another (to their own systems, the opportunity to save the data for their personal use or to begin storing their personal data in systems controlled by reliable third parties). In this respect, the right to data portability from one system to another complements the right of access to one’s personal data.
The right to data portability from one system to another under Article 20 of the General Data Protection Regulation also means that the data subjects have the right to receive their personal data in a structured, commonly used and machine-readable format so that they can easily transfer those data from one system to another system with another controller. The data may be transferred at the data subject’s request directly from one data controller to another if this is technically feasible (section 2 of Article 20). Data controllers are encouraged to develop compatible formats that enable the transfer of data from one system to another, although data controllers are not obliged to accept or maintain data processing systems that are technically compatible.
What is noteworthy about Article 20 of the General Data Protection Regulation is that the right to data portability applies to personal data processing activities that are based on:
- consent of the data subject (in accordance with Article 6(1)(a) or Article 9(2)(a) if the processing concerns special groups of personal data), or
- a contract to which the data subject is a party (in accordance with Article 6(1)(b)).
In other words, Article 20 of the General Data Protection Regulation must be complied with if the lawful basis for the processing of personal data is the consent of the data subject or the execution of a contract. The right only applies to personal data provided by the data subject to the data controller.
A request based on Article 20 of the General Data Protection Regulation 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.
Does not apply to this personal data register.
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
FI-00530 Helsinki, Finland
Postal address: PO Box 800
FI-00531 Helsinki, Finland
Telephone (switchboard): + 358 29 56 66700
Registry Office: + 358 29 566 6768
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 Administrative Register for Project Activities at Metropolia University of Applied Sciences is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and 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 Administrative Register for Project Activities at Metropolia have, as a general rule, been obtained from the data subjects themselves.
A person participating in a project has the right to decide on whether to participate in the project in question.
Metropolia collects and saves data on the persons who participate in projects coordinated by it but funded by an external party. For this reason, the personal data are occasionally processed in the manner required by the funder.
When an external funder is involved, the project auditors may in some cases request to monitor, assess and inspect the achievement of the goals of each project and the financial accounting for each project in a specific way.
The Administrative Register for Project Activities at Metropolia University of Applied Sciences and the data contained in it will not be used in automated decision-making or profiling.