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) and the data controller’s obligation to maintain a record of processing activities under its responsibility (GDPR Article 30), as well as on 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.
Metropolia’s Alumni Register
Name
Metropolia University of Applied Sciences Ltd
Contact information
Metropolia University of Applied Sciences Ltd (Business ID: 2094551-1)
Postal address: P.O. Box 4000, FI-00079 Metropolia
Visiting address: Myllypurontie 1, 00920 Helsinki, Finland
Telephone (switchboard): +358 9 7424 5000
Person responsible for the register at the data controller
Name: Riitta Konkola
Position: President, CEO of Metropolia University of Applied Sciences
Person responsible for the content of the register:
Name: Heidi Rontu
Position: Vice President, Education
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: heidi.rontu [at] metropolia.fi (heidi[dot]rontu[at]metropolia[dot]fi)
Contact details of the contact person for the register:
Name: Sini Vilpas
Position: Specialist, Student Affairs
Address: Metropolia University of Applied Sciences Ltd, PO Box 4000, FI-00079 METROPOLIA
Email: sini.vilpas [at] metropolia.fi (sini[dot]vilpas[at]metropolia[dot]fi)
Contact details for questions regarding the purpose of the register, email: alumni [at] metropolia.fi (alumni[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 Alumni Register of Metropolia University of Applied Sciences is to maintain the contact details of the alumni network’s members. The persons included in the Alumni Register have studied or worked at Metropolia University of Applied Sciences Ltd. The Alumni Register is mostly used to communicate with the alumni (e.g. alumni newsletters, communications about events). The Alumni Register is also used for promoting and deepening cooperation between Metropolia University of Applied Sciences Ltd and the alumni, including in the following activities:
- Mentoring for graduating students (graduation and employment)
- Maintenance of an alumni lecturer bank (expert lecturers)
- Conducting research and sharing the outcomes and new innovations resulting from the research
- Arranging alumni events
- Assisting in fundraising
Metropolia’s Alumni Register is a personal data register based on voluntary participation; it is used for managing alumni memberships, relations, activities and communications, as well as for marketing the alumni activities and services of Metropolia University of Applied Sciences Ltd. The data included in the Alumni Register may also be used for generating statistics to be used by Metropolia University of Applied Sciences Ltd. On Metropolia’s alumni web pages, there is a link to the Alumni Portal that enables access to the alumni system where the data concerning Metropolia’s alumni are managed. Metropolia urges its alumni to personally update their personal data in the Alumni Register through the portal. If a person wishes to leave the alumni network, the instructions for erasing one’s own data from the Alumni Register are available on Metropolia’s alumni pages.
Lawful basis for the processing of personal data:
The processing of the personal data contained in the Alumni Register of Metropolia University of Applied Sciences is based on the controller’s legitimate interests.
The applicability of legitimate interests as the lawful basis has been determined using a balance test. You can view the balance test (in Finnish) here.
The processing of the personal data contained in the Alumni Register of Metropolia University of Applied Sciences is based on the controller’s legitimate interests. The legitimate interests of the data controller are based on giving the staff of the UAS an opportunity to engage in social interaction and to maintain contact with former students and employees, as described in the purposes of the processing.
The data subjects of Metropolia’s Alumni Register are persons who have studies at and/or graduated from Metropolia University of Applied Sciences Ltd. Some persons who have worked at Metropolia have also wished to become members of Metropolia’s alumni network. The personal data of the data subjects of Metropolia’s Alumni Register are accessible through Metropolia’s alumni portal.
The following personal data are stored in Metropolia’s Alumni Register:
BASIC INFORMATION AND CONTACT DETAILS
- Basic information: forename(s), surname, date of birth, street address, postal code, city, telephone number, email address
UAS BACHELOR’S DEGREE INFORMATION FOR ALUMNI ACTIVITIES
- degree (UAS Bachelor’s), degree programme, year of graduation
UAS MASTER’S DEGREE INFORMATION FOR ALUMNI ACTIVITIES
- degree (UAS Master’s), degree programme, year of graduation
STAFF INFORMATION FOR ALUMNI ACTIVITIES
- retired, former employee
INFORMATION FOR ACTIVITIES FOR OTHER ALUMNI
- exchange student, student in further studies, studies interrupted, no degree, other alumni / additional information
INFORMATION ON COOPERATION
- role in the CRM system, information on possible participation in stakeholder meetings and/or alumni meetings, information on other cooperation conducted
LOG INFORMATION ON THE MANAGEMENT OF THE ALUMNI CUSTOMER RELATIONSHIP
- When the alumni customer relationship information is managed in Metropolia’s CRM system, log entries are created to be used for ensuring the service’s data security, developing technical aspects in the service and detecting, preventing and investigating faults (Information Society Code (917/2014), sections 138, 141, 144 and 272). The logs are stored for as long as is necessary for this purpose and they are not used for any other purposes.
The personal data contained in Metropolia’s Alumni Register are obtained from the OMA/Peppi student and education data system.
The data subjects are informed when they graduate (in Metropolia’s graduation instructions and in connection with the Metropolia degree certificate) that their data will be transferred to Metropolia’s Alumni Register, and at the same time they are informed of how they can erase their data from the Alumni Register if they wish, or how they can update their data directly in the system through a designated interface.
Access to the data contained in Metropolia’s Alumni Register 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 for processing personal data, Metropolia has concluded, or will conclude, personal data processing agreements in accordance with Article 28 of the GDPR with the following system providers or service providers:
Eduix Oy; OMA/Peppi student and education data system
The personal data contained in Metropolia’s Alumni Register are obtained from the OMA/Peppi student and education data system. The data are transferred from the OMA/Peppi system to Metropolia’s CRM system, which includes a separate section for the alumni. Metropolia’s CRM system is called the Microsoft Dynamics CRM (O365) system.
Microsoft Corporation; Microsoft Dynamics CRM (O365) system
The personal data contained in Metropolia’s Alumni Register are transferred at regular intervals from the OMA/Peppi system to Metropolia’s CRM system, which has a separate section for the alumni. On Metropolia’s alumni web pages, there is a link to the alumni portal that enables access to the alumni system, which is a part of Metropolia’s CRM system. The personal data of Metropolia’s alumni are managed in this system. Metropolia urges its alumni to personally update their personal data in the Alumni Register through the alumni portal interface. If a person wishes to completely leave the alumni network, the instructions for erasing one’s own data from the Alumni Register are available in the same alumni portal on Metropolia’s alumni pages.
Microsoft Corporation; SQL Server Reporting Services tool
The data contained in Metropolia’s Alumni Register are processed using the SQL Server Reporting Services tool.
eCraft Business Insight Oy Ab; Qlik Sense software
The data contained in Metropolia’s Alumni Register may be processed using the Qlik Sense software.
Eduix Oy; E-lomake (E-form) software
Participants can register for the events/additional training sessions in Metropolia’s Alumni Register using E-lomake, from which their data are transferred to an Excel sheet for managing participant information. Similarly, if there are external lecturers for the events/training sessions, they use E-lomake to provide their personal data for the payment of their fees. The necessary data are transferred to the data systems of the financial administration unit.
Lyyti Oy; Lyyti tool
Participants may also register for the events/additional training sessions in Metropolia’s Alumni Register using the Lyyti event management tool. For more information, see the Privacy Notice for Metropolia’s Event Management Register, which can be found in the Privacy Notices section on Metropolia’s public website.
Arc Technology Oy; HR (HRM) data system (e.g. payment of lecturers’ fees)
The payment of fees related to activities included in Metropolia’s Alumni Register takes place through the HR system (the same as Metropolia’s HRM system). For example, lecturers’ fees are handled through the HR (HRM) system.
Aditro Enterprise Ltd; Aditro Wintime financial administration system (invoicing of services)
All fee-based elements in alumni activities and the invoicing related to them are processed using the Aditro Wintime financial administration system, which is used throughout Metropolia University of Applied Sciences.
Liana Technologies Oy; Liana®Cloud newsletter tool
Electronic newsletters are sent through the sending system of the Liana®Cloud newsletter tool.
Metropolia’s email system (operated on Metropolia’s own server)
Email communications about Metropolia’s alumni activities are sent by email through Metropolia’s Microsoft Outlook Exchange email system. Although Metropolia has procured the email system as part of the Microsoft O365 service package, the system is operated on Metropolia’s own server.
As a general rule, the personal data contained in Metropolia’s Alumni Register 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, for example, India, a country where 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.
The data saved in Metropolia’s Alumni Register are erased when the data subject declares their intention to discontinue their membership in the alumni network. The data subjects also have the opportunity to erase their data from the register through the alumni portal.
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 disputes that their personal data are correct (right to rectify personal data), in which case processing will be restricted until the data controller can ascertain that the data are 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 for 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.
It should be noted with respect to Article 20 of the General Data Protection Regulation that the right to data portability only 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 categories of personal data), or
- a contract to which the data subject is 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 performance 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 the processing of personal data concerning them which is based on Article 6(1)(e) (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 the processing of collected personal data 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 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
FI-00530 Helsinki, Finland
Postal address: PO Box 800
FI-00531 Helsinki, Finland
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 Metropolia’s Alumni Register 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.
- Metropolia’s Alumni Register is used for managing the services and events of the alumni activities, providing information about them and arranging events.
- No one is obliged to become registered in Metropolia’s Alumni Register. If a data subject announces that they no longer wish to be registered in Metropolia’s Alumni Register, their personal data will be erased immediately. On the other hand, all alumni have the opportunity to personally erase their personal data from the Alumni Register. On the public web pages of Metropolia’s alumni activities, there is a link to the alumni portal that enables access to the alumni system, which is a part of Metropolia’s CRM system. The personal data of Metropolia’s alumni are managed in this system. Metropolia urges its alumni to personally update their personal data in the Alumni Register through the alumni portal interface. If a person wishes to leave the alumni network completely, the instructions for erasing one’s own data from the Alumni Register are available in the same alumni portal on Metropolia’s alumni pages.
- The data contained in Metropolia’s Alumni Register have been obtained from Metropolia’s student and education data system, the OMA/Peppi system and also from the data subjects themselves.
The personal data contained in Metropolia’s Alumni Register are not used for automated decision-making or profiling.