Metropolia’s Human Resources Management Register

This Privacy Notice is based on the EU’s General Data Protection Regulation (2016/679, “GDPR”), namely on 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.

Purpose of the processing of personal data:

The purpose of processing Metropolia’s Human Resources Management Register and the data it contains is to perform the statutory obligations of Metropolia University of Applied Sciences Ltd with the help of the data controller’s (Metropolia University of Applied Sciences Ltd) Human Resources Management (personnel services, HRM).

Human Resources Management processes data for the following purposes:

personnel planning and reporting;
recruitment and induction of employees;
payroll calculation, salary payment and management of the remuneration of the employees;
payment of scholarships and travel and expense invoices;
management of annual holidays and other holidays;
management of membership affairs;
equality and equal opportunities;
management of employment relationships;
management and development of competence and providing support for working capacity;
guidance and monitoring of activities (e.g. personnel surveys and quality)
supporting working capacity and providing occupational health care and wellbeing services;
workplace accident insurance;
cooperation at the workplace;

Lawful basis for the processing of personal data:

The processing of the personal data contained in Metropolia’s Human Resources Management Register is necessary for the performance of a contract (such as an employment contract or other assignment contract) to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract, or for the purposes of the legitimate interests pursued by the controller or by a third party (EU’s General Data Protection Regulation, “GDPR”, Article 6(1)(b) and 6(1)(f)).

In addition, the processing of the personal data is necessary for compliance with a legal obligation to which the controller is subject (GDPR Article 6(1)(c)). Metropolia University of Applied Sciences Ltd fulfils its statutory obligations as an employer while performing human resources management tasks by following the applicable provisions of the Employment Contracts Act, the Act on Co-operation within Undertakings, the Act on Occupational Safety and Health Enforcement and Cooperation on Occupational Safety and Health at Workplaces, the Occupational Safety and Health Act, and the Occupational Health Care Act, as well as the provisions of the collective agreement.

In the case of personal data belonging to special categories of personal data (incl. trade union membership), which are classified as sensitive personal data under the GDPR, processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment law in so far as it is authorised by Union or Member State law or a collective agreement providing for appropriate safeguards for the fundamental rights and the interests of the data subject (GDPR Article 9(2)(b)).

In certain parts, the processing is also based on the consent of the data subject (e.g. health data) for the processing of special categories of personal data (GDPR Article 9).

Personal data are disclosed from Metropolia’s Human Resources Management Register to the following recipient groups:

Tax Administration
pension insurance companies
insurance companies
occupational health care and wellbeing services
Statistics Finland
trade unions
Social Insurance Institution of Finland (Kela)
TE Centre (employment services)
parties providing training to the staff
funders of mobility projects (European Commission or Finnish National Agency for Education) and the national office of Erasmus+ (Finnish National Agency for Education)
university or other organisation receiving a lecturer or staff visit
Centre for Occupational Safety
Ministry of Education and Culture
banks and other providers of salary/fee payment services

Human Resources Management only discloses personal data to parties that have a statutory right to receive information for a purpose specified by law, or to which the disclosure of data is necessary for the performance of tasks related to employment relationship matters and employer activities, or to which the data subject has consented to the disclosure of data. Personal data may only be processed by persons whose job duties require it. Access to personal data is provided through encrypted data connections and data networks. Paper documents and printouts are stored in locked premises and cabinets.

Access to the personal data contained in Metropolia’s Human Resources Management 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 by Metropolia’s Human Resources Management Register, personal data processing agreements in accordance with Article 28 of the GDPR have been or will be concluded with the following cooperation partners:

ARC Technology Oy; HR system

The HR (HRM) system is used to process personnel affairs at Metropolia from the start of each employment relationship until it ends.The staff can enter reports regarding absences and other matters related to the employment relationship into the system. The user rights to the HR system have been given to Metropolia’s staff, supervisors and Human Resources Management. The HR system is operated on a Metropolia server. No data are disclosed to ARC Technology Oy, as the system is operated on a Metropolia server.

DevNet Oy; Promid working hours management system

Metropolia’s staff can add and correct timestamps in the Promid working hours management system. The employee/lecturer and their supervisor can review the timestamp history in the service.

Aditro Enterprise Ltd; Wintime financial administration system (invoicing of services)

All the fees and invoicing related to Human Resources Management are processed using the Aditro Wintime financial administration system, which is used throughout Metropolia University of Applied Sciences.

Terveystalo Plc; Sirius working capacity control system

The Sirius working capacity control system (system for monitoring and managing risks affecting working capacity) maintained by Terveystalo Plc is used for identifying risks affecting working capacity, and determining and following up on the necessary measures.

User rights to the Sirius system are given to Metropolia’s Human Resources Management as well as to supervisors concerning data in their area of responsibility.

Visma Public Oy (Visma Public); Personec F payroll management system

The Personec F payroll management system maintained by Visma Public Oy (Visma Public) is used to manage and carry out the payment of salaries and fees to the staff. The employees of Metropolia’s payroll administration have user rights to the salary payment system.

Microsoft Corporation; Metropolia’s email system

Information about the activities of Metropolia’s Human Resources Management as well as invitations to surveys 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.

Leijonaverkot Oy (part of the Erillisverkot Group, formerly Deltagon Group Oy) and secure mail (Deltagon’s) sec@gw secure mail solution)

The email encryption solution procured by Metropolia, namely the Deltagon sec@gwsecure mail solution, may be used for the transmission of sensitive personal data and confidential documents to email addresses outside Metropolia (when email is sent to and from an email address that does not have the “@metropolia.fi” domain).

Eduix Oy; E-lomake (E-form) software

The E-lomake software can be used to conduct surveys intended for the staff of Human Resources Management.

Orange Advertising Oy and Eduix Oy; People Finder search service

People Finder includes a search function with which the user can search for the contact details and qualification information of Metropolia’s students or staff or the employees of partners (e.g. caretakers, restaurant staff, priests at educational institutions). In addition to the mandatory basic details, the data subject may add more information about themselves, such as their competence. The facial photos of the data subjects are also collected and stored in the service with the express consent of the data subjects. The People Finder service is available on Metropolia’s internal OMA intranet as well as on Metropolia’s public website for stakeholders.

Eduix Oy; OMA intranet

The internal OMA intranet of Metropolia University of Applied Sciences serves as an arena for communications, marketing and announcements. OMA intranet includes descriptions of the various units/services as well as the contact details of the responsible persons in connection with these.

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), dpo [at] metropolia.fi (dpo[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.

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.

Privacy notice: Metropolia’s Human Resources Management Register